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Special Time-Sensitive Complications for the 2025 Proxy Season

As most public companies know, shareholder outreach is often an important part of the playbook when a company is seeking approval of compensation-related proposals at an annual meeting. A company may engage with shareholders...more

Policy Updates and Considerations for Proxy Season

Public companies find themselves rethinking disclosures relating to the diversity of their board and their director recruitment practices as they head into proxy season, given recent developments – including the US Court of...more

SEC Staff Adopts Significant New Guidance Affecting Shareholder Proposals and Engagement

On February 11 and 12, 2025, the staff of the Division of Corporation Finance (Staff) of the Securities and Exchange Commission (SEC) provided a pre-Valentine’s Day treat for public companies and shareholders to digest in the...more

BlackRock and Vanguard Release 2025 Proxy Voting Guidelines

On January 31, 2025, Vanguard issued its proxy voting policy for US portfolio companies, following the publication of BlackRock’s proxy voting guidelines for benchmark policies – US securities in December 2024. The updates...more

Should SEC Revisit Executive Security Perquisite Disclosure?

The recent homicide of UnitedHealthcare CEO Brian Thompson has put a spotlight on executive security and has prompted many companies to reassess how they are protecting their top executives. We also believe that in the wake...more

SEC Reporting Implications for Publicly Traded Companies Impacted by CrowdStrike Defective Software Update

There are a number of US Securities and Exchange Commission (SEC) reporting implications arising from the server-related outages caused by CrowdStrike’s defective software update on July 19, 2024, and their impacts on public...more

SEC Settles Charges Against RR Donnelley Related to Cybersecurity Incident Disclosure and Internal Access Controls

On June 18, 2024, the Securities and Exchange Commission (SEC) announced that it had settled claims against RR Donnelley (RRD) related to a 2021 ransomware and cyber extortion attack. Despite RRD having discovered and...more

US Supreme Court: Pure Omissions Not Actionable Under Rule 10b-5(b)

On April 12, 2024, the US Supreme Court reversed the US Court of Appeals for the Second Circuit’s decision in Macquarie v. Moab Partners and held that a pure omission cannot form the basis of a securities fraud claim under...more

Key Considerations for Form 8-K Cybersecurity Materiality Determinations

With 8-K reporting obligations for “material” cybersecurity incidents under the new Securities and Exchange Commission (SEC) rules becoming effective as of December 18, 2023, most companies will soon be tasked with making...more

SEC Adopts Comprehensive Cybersecurity Disclosure Requirements

On July 26, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to mandate standardized cybersecurity disclosures by public companies. The final rules will...more

SEC Final Share Repurchase Disclosure Rules Less Burdensome Than Expected

On May 3, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to require enhanced disclosure about issuer share repurchases under the Securities Exchange Act of 1934, as amended....more

Filling the Gaps: SEC Adopts Final Rules on 10b5-1 Trading Plans and Related Disclosures

The Securities and Exchange Commission adopted final rules that impose new conditions on the availability of the Rule 10b5-1 affirmative defense to insider trading and require enhanced disclosures regarding the adoption,...more

SEC Adopts Long-Considered Pay-Versus-Performance Disclosure Rule

Background On August 25, 2022, the Securities and Exchange Commission (SEC) adopted pay-versus-performance rules (codified in Item 402(v) of Regulation S-K), 12 years after the Dodd-Frank Wall Street Reform and Consumer...more

SEC Proposes Watershed Climate-Related Disclosure Requirements

On March 21, 2022, the Securities and Exchange Commission announced a long-awaited proposal that would require public companies to disclose extensive climate-related information in their registration statements and periodic...more

SEC Proposes Sweeping Cybersecurity Disclosure Framework

On March 9, 2022, the Securities and Exchange Commission announced that it proposed rules that would expressly mandate cybersecurity disclosures by public companies. The rules would require disclosure of material...more

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