In January 2020, Institutional Shareholder Services and the U.S. Securities and Exchange Commission agreed to stay litigation filed by ISS in October challenging the SEC’s interpretation and guidance related to voting...more
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
On August 20, 2019, the SEC staff published new interpretations in the form of Compliance and Disclosure Interpretations regarding Inline XBRL, which affirmed the guidance we previously posted about the new exhibit 104 cover...more
On October 16, 2018, the Securities and Exchange Commission (SEC) issued a report outlining an investigation conducted by the SEC’s Division of Enforcement related to the internal accounting controls at nine public companies...more
For the second time this year, a Commodity Futures Trading Commission-registered futures commission merchant and National Futures Association member was sanctioned by both regulators for allegedly not supervising post-trade...more
The Securities and Exchange Commission (“SEC”) released expansive interpretive guidance (“2018 Guidance”), posted February 21, 2018, further building upon its far-reaching cybersecurity guidance provided in 2011. Below are...more
The U.S. Securities and Exchange Commission has issued guidance on cybersecurity disclosure. Companies must establish and maintain appropriate disclosure controls and procedures to make accurate and timely disclosures of...more
SEC Chair Speaks About ICOs and Virtual Currencies - In a statement released on December 11, 2017, Jay Clayton, Chair of the U.S. Securities and Exchange Commission (SEC), offered his views about initial coin offerings...more
On September 21, 2017, the Securities and Exchange Commission announced that it approved interpretive guidance to assist registrants in their efforts to comply with the pay ratio disclosure requirement in Item 402(u) of...more
On September 21, 2017, the U.S. Securities and Exchange Commission (SEC) released several items that provide additional guidance on the CEO Pay Ratio Rule (the “Rule”): (1) SEC interpretive guidance; (2) Revised pay...more
In response to a request for interpretative guidance, the U.S. Securities and Exchange Commission staff (staff) advised on January 11, 2017 that Section 22(d) of the Investment Company Act of 1940 does not prevent a broker...more
Background - In recent months, senior SEC officials have repeatedly cautioned public companies about the use of non-GAAP financial measures. These include statements by SEC Chair Mary Jo White, SEC Chief Accountant James...more
On March 14, 2016, the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) issued interpretive guidance (the “Guidance”) affirming that, in a traditional UPREIT structure, the...more
On May 12, 2015, the Commodity Futures Trading Commission (CFTC) issued revised interpretive guidance for forward contracts with embedded volumetric optionality (EVO). In 2012, the CFTC and Securities and Exchange Commission...more