The SEC has adopted rules prohibiting “bad actors” from using Rule 506 after September 23, 2013 (the effective date of the rules), or if prohibited conduct occurred prior to the effective date of the rules, the prohibition...more
The SEC has proposed rules related to pay ratio disclosures required by Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. It works like this...
Courts have recently rendered two say-on-pay decisions. ...more
The SEC has issued nine frequently asked questions, or FAQs, on the disclosure of payments by resource extraction issuers....more
A California court recently granted Symantec’s demurrer in a lawsuit that challenged its proxy statement disclosures in connection with an annual meeting. For those of us who haven’t been to law school recently, a demurrer...more
The CFPB has announced its proposed policy to allow companies to test new consumer disclosures on a case-by-case basis. As part of its Project Catalyst initiative, and in line with its statutory authority, the CFPB’s goal is...more