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To be or not to be a “non-Rule 10b5-1 trading arrangement” – that is the question!

A “Rule 10b5-1 plan” is intended to satisfy the affirmative defense provided in Rule 10b5-1(c), the rule that provides an affirmative defense to an allegation of having traded on the basis of material nonpublic information...more

An Analysis of the SEC’s Pay Versus Performance Rules - A Step-by-Step Guide

We have prepared this guide to assist our clients as they prepare to implement the SEC’s new “Pay Versus Performance” (“PVP”) Rules. On Aug. 25, 2022, after a twelve-year delay, the SEC adopted rules implementing Section...more

Never Too Late – SEC Enacts Pay vs. Performance Disclosure Rules

A mere 12 years after they were mandated by Dodd-Frank, the SEC adopted so-called “pay versus performance” rules on August 25, 2022. The rules require companies to provide a new table in their proxy or information statements,...more

July 2020 Task List for Accelerated Filers

Companies that are accelerated filers have a number of things to consider this month. In-line XBRL Is Now Required - First — don’t forget that the in-line XBRL tagging requirements (including for cover pages) have now...more

SEC Provides Interpretive Guidance on Inline XBRL

On August 20, 2019, the SEC provided interpretive guidance in the form of nine new Compliance and Disclosure Interpretations (“C&DIs”) on the new inline XBRL and related exhibit requirements....more

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