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Reporting Requirements Securities and Exchange Commission (SEC)

Seward & Kissel LLP

Recent SEC Enforcements for Violations of Whistleblower Protection Rule

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On September 9, 2024, the Securities and Exchange Commission (“SEC”) announced it settled enforcement actions against seven public companies for alleged violations of its whistleblower protection rule in their...more

Cooley LLP

Amended Filing Deadlines for Schedule 13G Filers Go Into Effect September 30, 2024

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In 2023, the Securities and Exchange Commission (SEC) adopted wide-ranging rule changes applicable to beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act. These rule changes are...more

Bass, Berry & Sims PLC

Recyclable K-Cups: Investors Beware?

Bass, Berry & Sims PLC on

On September 10, the Securities and Exchange Commission (the Commission or SEC) charged Keurig Dr Pepper Inc. (Keurig) for making inaccurate statements about the recyclability of its K-Cup single-use beverage pods.  Without...more

Skadden, Arps, Slate, Meagher & Flom LLP

How and When SEC Recordkeeping Rules May Apply to AI-Generated Content

AI has revolutionized the way many businesses operate. Firms in the financial sector are eager to take advantage of rapidly developing technologies but do not want to risk running afoul of relevant Securities and Exchange...more

Ballard Spahr LLP

SEC Announces Settlements with Seven Public Companies for Violations of Exchange Act Whistleblower Protections in Employee and...

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The SEC has begun to bring enforcement actions against companies whose employment and client agreements could appear to infringe on the right to report cases in violation of Section 21f-17(a) of the Exchange Act. On September...more

Wilson Sonsini Goodrich & Rosati

REMINDER: New Schedule 13G Filing Deadlines

In October 2023, the U.S. Securities and Exchange Commission (SEC) approved final rules amending the beneficial ownership reporting requirements under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (Exchange...more

Fenwick & West LLP

The CrowdStrike Ripple Effect: Ongoing Reporting Implications for Public Companies

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Companies impacted by CrowdStrike’s defective software update should consider the following long-term reporting implications...more

Proskauer - Regulatory & Compliance

New filing deadlines for Schedule 13G effective September 30

The deadlines for filing and amending Schedule 13Gs are about to change, and regular 13G amendments will now be due on a quarterly basis instead of annually. As we discussed in our alert last fall (available here), in...more

K&L Gates LLP

Checked Swing—SEC Does Not Adopt "Swing Pricing" or a "Hard Close" for Now, but Only Provides Liquidity Guidance and Amendments to...

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EXECUTIVE SUMMARY On 28 August, 2024, the Securities and Exchange Commission (SEC) adopted amendments to reporting forms for registered investment companies (funds) that will (1) require funds to file monthly (rather than...more

Cooley LLP

US Corporate Transparency Act Reporting Deadline Approaching – What You Need to Know

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Millions of existing companies formed or registered in the US on or before December 31, 2023, are required to file beneficial ownership information (BOI) reports on or before January 1, 2025, pursuant to the requirements of...more

Bass, Berry & Sims PLC

The Time is Here: Public Companies Should be Mindful of the Upcoming Insider Trading Policy Form 10-K Exhibit Filing Requirement

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In connection with the upcoming Form 10-K/proxy season, public companies with a fiscal year ending on December 31 will be required, for the first time, to publicly file their insider trading policies as exhibits to their...more

Jenner & Block

Client Alert: Key Takeaways from the SEC’s Latest Enforcement Sweep Regarding Violations of the Whistleblower Protections Rule

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Earlier this week, the SEC announced an enforcement sweep charging seven public companies with violating the whistleblower protections rule in various employment-related agreements. These charges reflect the SEC’s continuing...more

Hogan Lovells

Mandatory compliance nears for remaining Section 13 reporting requirements - SEC Update

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The last two mandatory compliance dates under the SEC’s amendments to Exchange Act Regulation 13D-G adopted in October 2023 are fast approaching. We discussed the amendments in our SEC Update available here. Beginning on...more

Cohen & Gresser LLP

Upcoming Changes to Schedule 13G Reporting

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So long ago that it may have slipped from memory, the U.S. Securities and Exchange Commission (“SEC”) adopted changes to the regime for reporting beneficial interests in publicly traded equity securities on Schedule 13G. The...more

Troutman Pepper

SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

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I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - September 2024

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Troutman Pepper

New Accelerated Schedule 13G Reporting Deadlines Effective September 30

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The Securities and Exchange Commission’s (SEC) new accelerated Schedule 13G filing deadlines will become effective on September 30, 2024. On October 10, 2023, as part of an initiative to modernize beneficial ownership...more

Fenwick & West LLP

New Schedule 13G filing deadlines looming

Fenwick & West LLP on

New filing deadlines for Schedule 13G become effective on September 30. In October 2023, the SEC adopted new rules governing beneficial ownership reporting, including accelerating the filing deadlines for Schedule 13G and...more

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Schedule 13G Accelerated Filing Deadlines Effective September 30, 2024

As we noted in prior client alerts (available here and here), in 2023 the Securities and Exchange Commission (SEC) adopted amendments to its beneficial ownership rules. The amended rules include accelerated filing deadlines...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Face Challenges as They Prepare To Comply With the EU’s Sustainability Reporting Law

As the deadlines approach for multinationals to make their first disclosures under the Corporate Sustainability Reporting Directive (CSRD), the EU’s new sustainability reporting law, they are confronting the significant time...more

Morgan Lewis

SEC Amends Registered Fund Reporting Requirements, Issues Guidance on Liquidity Risk Management Programs

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The US Securities and Exchange Commission (SEC), by a 3-2 vote, recently adopted amendments to registered fund reporting requirements on Form N-PORT and Form N-CEN and provided guidance on open-end funds’ liquidity risk...more

Sullivan & Worcester

SEC Adopts Amendments to Form N-PORT and Form N-CEN Reporting Relating to Liquidity Risk Management; Issues Guidance on Open-End...

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On August 28, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments to reporting requirements on Forms N-PORT and N-CEN that apply to certain registered investment companies, including registered open-end...more

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

Dechert LLP

SEC Enhances Reporting on Forms N-PORT & N-CEN; Issues Liquidity Guidance

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On August 28, 2024, the SEC, by a vote of three to two, adopted amendments (Amendments) to the current reporting requirements on Form N-PORT and Form N-CEN and provided guidance (Liquidity Rule Guidance) related to liquidity...more

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