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Looking Ahead to the 10-K and Proxy Season: New Requirements and Considerations for the 2025 Reporting Season

As we approach 2025, we want to remind registrants about several new rules that will impact disclosure for the 2024 Form 10-K and 2025 proxy season, note the 2025 deadlines for filings with the Securities and Exchange...more

SEC Charges Public Companies with Misleading Cyber Disclosures

On October 22, 2024, the Securities and Exchange Commission (SEC) announced that it had charged four companies with making materially misleading disclosures regarding cybersecurity risks and intrusions, with one company also...more

SEC Levies Extensive Penalties for Late Beneficial Ownership Reporting and Insider Transaction Reports

On September 25, 2024, the Securities and Exchange Commission (SEC) announced settlements with 23 entities and individuals for untimely reporting related to their respective holdings and transactions in public company stock....more

Thought Leadership SEC Charges Public Companies with Violations of Whistleblower Protection Rule

On September 9, 2024, the Securities and Exchange Commission (SEC) announced settlements with seven public companies for using employment, separation, and other agreements that violated rules prohibiting actions to impede...more

Court Limits an Early SEC Effort at Cybersecurity Enforcement

On July 18, 2024, Judge Paul A. Engelmeyer of the U.S. District Court for the Southern District of New York issued a 107-page opinion dismissing most of the Securities and Exchange Commission’s (SEC) case against SolarWinds...more

Supreme Court Holds Pure "Omissions" in MD&A Disclosure Cannot Support Liability Under Rule 10b-5

On April 12, 2024, the U.S. Supreme Court held in Macquarie Infrastructure Corp. v. Moab Partners, L.P., in a unanimous opinion authored by Justice Sonia Sotomayor, that “pure omissions” made in required disclosures do not...more

SEC Puts Climate Disclosure Rules on Hold Pending Judicial Review

On April 4, 2024, the Securities and Exchange Commission (SEC) released an order issuing a stay of the newly adopted SEC climate disclosure rules (our guide to the new climate disclosure rules is available here). In issuing...more

Challenges to SEC Climate Disclosure Rules Consolidated in Eighth Circuit Court of Appeals

On March 21, 2024, the lottery conducted by the Judicial Panel on Multidistrict Litigation selected the U.S. Court of Appeals for the Eighth Circuit as the venue for hearing a case consolidating nine lawsuits against the...more

A Guide to the SEC's New Climate Disclosure Rules

On March 6, 2024, the Securities and Exchange Commission (SEC) adopted climate disclosure rules which will require registrants to disclose detailed new climate-related disclosures in annual reports and registration...more

Fifth Circuit Temporarily Pauses SEC Climate Disclosure Rules

On March 15, 2024, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit temporarily stayed the recently adopted Securities and Exchange Commission (SEC) climate disclosure rules, blocking their...more

SEC Adopts Final Climate-Related Disclosure Rules

On March 6, 2024, the Securities and Exchange Commission (SEC) adopted climate disclosure rules which will require registrants to disclose detailed new climate-related disclosures in annual reports and registration...more

Lessons from the First Year of Pay vs. Performance Disclosures

As we approach the 2024 proxy season, companies are preparing for the second year of compliance with the pay vs. performance (PvP) disclosure required under Item 402(v) of Regulation S-K. As a reminder, under Item 402(v) of...more

NYSE Publishes 2024 Listed Company Compliance Guidance Memo

On January 31, 2024, the New York Stock Exchange (NYSE) published its 2024 Listed Company Compliance Guidance Memo. The NYSE Memo contains general guidance with important reminders for all NYSE listed companies, along with a...more

SEC Adopts Amendments to Beneficial Ownership Reporting Rules

On October 10, 2023, the Securities and Exchange Commission (SEC) adopted amendments to the reporting requirements relating to beneficial ownership. As outlined below, the amendments (i) shorten the deadlines to file for...more

Looking Ahead to the 10-K and Proxy Season

As the calendar year flips over to 2024, we want to remind registrants about several new rules that will impact disclosure for the 2023 Form 10-K and 2024 proxy season, update the status of some pending Securities and...more

SEC Heightens Issuers' Cybersecurity Disclosure Requirements

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted final rules regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. The final rules require...more

SEC Heightens Issuers' Share Repurchase Disclosure Requirements

On May 3, 2023, the Securities and Exchange Commission (SEC) adopted amendments to the disclosure requirements relating to issuers’ repurchases of their equity securities. As outlined below, the amendments require additional...more

New Rule 10b5-1 Disclosure Requirements Prompt Issuers to Reconsider Existing Compliance

On December 14, 2022, the Securities and Exchange Commission (SEC) adopted several amendments and new disclosure requirements to address what it viewed as potentially abusive practices associated with Rule 10b5-1 plans,...more

Preparing for December 1 Compliance with NYSE and Nasdaq Clawback Policy Listing Standards

On June 9, 2023, the Securities and Exchange Commission (SEC) approved the executive compensation clawback listing standards and relevant amendments proposed by the New York Stock Exchange (NYSE) and the Nasdaq Stock Market...more

SEC Adopts Final Executive Compensation Clawback Rules: What This Means and How to Prepare

On October 26, 2022, the Securities and Exchange Commission (SEC) adopted final rules that will require public companies to implement policies to recover, or claw back, erroneously awarded incentive-based compensation from...more

SEC to Mandate Electronic Filing of Form 144 via EDGAR

On June 2, 2022 the Securities and Exchange Commission (SEC) adopted rule amendments that will require all Forms 144 to be filed electronically on EDGAR, rather than mailing a traditional paper filing or utilizing the option...more

The SEC's Long-Delayed Dodd-Frank Pay-Versus-Performance Disclosure Requirements Have Finally Arrived

On August 25, 2022, the Securities and Exchange Commission (SEC) adopted the pay-versus-performance disclosure requirements that had been in the works for years. The SEC originally proposed pay versus performance rules...more

SEC Revises Integration Framework And Its Associated Safe Harbors

The Securities and Exchange Commission (SEC) recently published extensive rules to modernize the private placement framework of the federal securities laws. On March 15, 2021, the Final Rules became effective. The SEC goal...more

Modernizing The Private Placement Framework: A Summary Of Recent SEC Rulemaking

The Securities and Exchange Commission (SEC) recently published extensive rules aimed toward modernizing aspects of the private placement framework of the federal securities laws. On January 14, 2021, the Final Rules were...more

SEC Modernizes And Expands "Accredited Investor" Definition

On August 26, 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments to the “accredited investor” definition in Rule 501 of Regulation D. Below, we summarize the key takeaways from this change, as well as...more

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