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U.S. Companies and U.S. Persons now exempted from CTA; April 25, 2025 deadline set for Foreign Companies

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury published its revised Corporate Transparency Act (CTA) Beneficial Ownership Information (BOI) reporting rule, also known...more

CTA Effectively Paused: No Enforcement Actions Until FinCEN Issues New Interim Final Rule and Revised Reporting Deadlines

On February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury announced that it will not be issuing any fines or penalties or taking any other enforcement actions against any...more

Second CTA Nationwide Injunction Stayed; New March 21, 2025 Filing Deadline

On January 23, 2025, the U.S. Supreme Court granted the government’s motion to stay a nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA) issued by a federal judge in Texas (Texas...more

The Corporate Transparency Act on Pause Again as of December 26: Nationwide Injunction Reinstated

The U.S. Court of Appeals for the Fifth Circuit has VACATED its recent stay of the nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (CTA). The court vacated its earlier stay "in...more

Corporate Transparency Act Nationwide Injunction Stayed; New Filing Deadline is January 13, 2025

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted the government's emergency motion to stay the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA)....more

Nationwide Injunction Halts Corporate Transparency Act Enforcement

On Dec. 3, 2024, in the case of Texas Top Cop Shop, Inc. v. Garland, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against the enforcement of the Corporate Transparency...more

The Final Countdown: Major CTA Reporting Deadline Rapidly Approaching

Barring any unforeseen changes, the Corporate Transparency Act's (CTA) major reporting deadline arrives on January 1, 2025. The CTA requires all existing reporting companies (those entities formed prior to January 1, 2024) to...more

The Corporate Transparency Act Found Unconstitutional, Now What?

On Friday March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (CTA) is an unconstitutional overreach of Congress's enumerated powers in...more

SEC Eases Pay Ratio Rule

Two pieces of guidance emerged from the Securities and Exchange Commission on September 21, 2017, with respect to the pay ratio rule. The guidance was issued by the Commission and the Commission's Division of Corporation...more

What Effect Will the New Revenue Recognition Standard Have on M&A?

The Financial Accounting Standards Board's new revenue recognition standard is expected to have wide-ranging effects on M&A transactions. The new revenue recognition standard under GAAP will be applicable to public companies...more

FDIC Provides Corporate Governance Guidance to Community Banks

The FDIC issued a special edition of Supervisory Insights, “A Community Bank Director’s Guide to Corporate Governance: 21st Century Reflections on the FDIC Pocket Guide for Directors.” This special corporate governance...more

T+2 Settlement Gathers Momentum

FINRA is seeking comment on proposed amendments to FINRA rules shortening the securities settlement cycle to two days. The rulemaking notice cites a September 2015 letter in which SEC Chair White responded to industry groups...more

SEC Publishes 2015 Whistleblower Report

The SEC published its 2015 Annual Report on the Dodd-Frank Whistleblower Program. The report indicates the SEC received 3,923 tips in fiscal year 2015, compared to 3,620 tips in fiscal year 2014. From fiscal year 2012, the...more

CFTC Makes Second Whistleblower Award

The U.S. Commodity Futures Trading Commission, or CFTC, announced that it will make an award of approximately $290,000 to a whistleblower for providing valuable information about violations of the Commodity Exchange Act....more

SEC Charges Investment Adviser with Cybersecurity Violations

The SEC recently commenced a settled enforcement action against an investment adviser, R.T. Jones Capital Equities Management, Inc., for cybersecurity matters. Press reports indicate this is the first such case of its kind. ...more

ISS Commences 2016 Proxy Voting Policy Survey

ISS has commenced its 2016 proxy voting policy survey. Some of the issues ISS seeks comment on include: - Is it appropriate to use non-GAAP or adjusted GAAP metrics for compensation programs? - What types of equity...more

SEC Seeking Comment on Possible Revisions to Audit Committee Disclosures

The SEC has issued a concept release to seek public comment regarding audit committee reporting requirements, with a focus on the audit committee’s reporting of its responsibilities with respect to its oversight of the...more

MSRB Provides Guidance on Developing Supervision and Compliance Programs for Municipal Advisors

Rule G-44 of the Municipal Securities Rulemaking Board, or MSRB, became effective on April 23, 2015. That Rule establishes the supervisory and compliance obligations of municipal advisors. The MSRB has provided an...more

Obligations Under Earn-Outs Are Limited to What the Words Say

The stockholders of Cyveillance, Inc., sold their company for $40 million up-front and a $40 million earn-out if the company’s revenues reached a certain level. Section 5.4 of the merger agreement prohibited the buyer from...more

MSRB Moves Foward Professional Qualification Standards For Municipal Advisors

The Municipal Securities Rulemaking Board, or MSRB, has received approval from the SEC to create baseline standards of professional qualification for municipal advisors. The new standards will be incorporated through...more

NYSE Proposes to Clarify Proxy Solicitation Mechanics

The NYSE proposes to amend Section 402.05 of the Listed Company Manual to clarify that listed companies soliciting proxy material through brokers or other entities must comply with SEC Rule 14a-13. Rule 14a-13 mandates...more

ISS Posts FAQs on Compensation Policies

ISS has posted new FAQs on U.S. compensation policies. There are 104 FAQs spanning 43 pages. Given their breadth, they are difficult to summarize. But they cover topics ranging from say-on-pay, pay-for-performance...more

AICPA Provides Guidance on Conflict Minerals Representation Letters

A standard part of every financial statement audit is providing the auditor a representation letter reaffirming certain assertions that are implicit in preparation of financial statements in accordance with GAAP. The AICPA...more

SEC Eases Terms for 5-Day Debt Tender Offers

The SEC recently provided no-action relief for five-day tender offers. The new no-action letter eases requirements in the following areas: - The tender offer must be open for five business days rather than a seven to...more

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