News & Analysis as of

Capital Markets SEC Comment Letter Process

Skadden, Arps, Slate, Meagher & Flom LLP

Capital Markets - 2022 Capital Markets and Corporate Governance Regulatory Review

To prepare for 2023, reporting companies should be aware of applicable SEC filing deadlines and financial statement “staleness” dates, as well as regulatory reforms that may affect the preparation and contents of disclosures...more

Orrick, Herrington & Sutcliffe LLP

Comment Period Reopened for Climate and Cybersecurity Proposals, Among Others

On Friday, October 7, 2022, the Securities and Exchange Commission (the “SEC”) reopened the public comment periods for eleven rulemaking proposals and one request for comment due to a technical error that prevented the SEC...more

Jones Day

Comment Letter Submitted on SEC’s Proposed Climate-Related Disclosure Rules

Jones Day on

We believe our proposed changes support all market participants' common objectives of investor protection and fair and efficient capital markets. ...more

Cozen O'Connor

SEC Releases Sample Comment Letter for Issuers Conducting Offerings During Periods of Volatility

Cozen O'Connor on

On February 8, 2021, the Division of Corporation Finance of the Securities and Exchange Commission (SEC) published a sample comment letter that the SEC might send to issuers that conduct securities offerings during periods of...more

Farrell Fritz, P.C.

Gig Stock: Extension of Rule 701 Exemption for Compensatory Equity Proposed for Gig Economy Participants

Farrell Fritz, P.C. on

Private companies in the gig economy like Uber, Airbnb and GrubHub would love to issue compensatory equity to their platform participants, just like they’re able to do with their employees. ...more

Morrison & Foerster LLP

Practice Pointers: Anticipating and Addressing SEC Comments on Non-GAAP Financial Measures - February 2017

The use of non-GAAP financial measures by public companies continues to be an area of growing concern for the Securities and Exchange Commission (“SEC”). Since the staff of the SEC’s Division of Corporation Finance (the...more

McDermott Will & Emery

Capital Markets & Public Companies Quarterly: Potential Shift in SEC’s Proxy Access No-Action Policy and Other New Guidance from...

McDermott Will & Emery on

The third quarter of 2016 saw the US Securities and Exchange Commission (SEC) carry forward its momentum from an active second quarter. Recent developments include new SEC Compliance & Disclosure Interpretations (C&DI) and...more

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