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SEC Abandons Climate-Related Disclosure Litigation — What Next?

The Securities and Exchange Commission (SEC) recently informed the U.S. Court of Appeals for the Eighth Circuit that it will no longer defend its March 6, 2024, rule requiring that companies disclose climate-related risks and...more

Diversity in the Boardroom: Nasdaq’s Diversity Disclosure Rules Struck Down by En Banc Fifth Circuit Court of Appeals

In what will likely mark the final outcome, the U.S. Court of Appeals for the Fifth Circuit, sitting en banc, struck down the Nasdaq Stock Market’s diversity-disclosure framework on Dec. 11, 2024. The Nasdaq rules issue —...more

Advisory Firm Pays $17.5M Civil Penalty To Settle SEC Charges for Making Misrepresentations Regarding ESG Considerations in...

On Nov. 8, 2024, the Securities and Exchange Commission (SEC) announced that it charged Invesco Advisers, Inc. with making materially misleading statements about the percentage of its assets under management (AUM) that...more

SEC Announces Penalties Against Four Companies for Downplaying Severity of SolarWinds Cybersecurity Breach in Disclosures

On Oct. 22, 2024, the Securities and Exchange Commission announced that it charged four technology companies with making materially misleading disclosures about the effect the SolarWinds cyberattack had on these issuers. To...more

SEC Division of Corporation Finance Clarifies Form 8-K Disclosures of Material Cybersecurity Incidents

On May 21, 2024, the director of the SEC’s Division of Corporation Finance, Erik Gerding, issued a statement regarding the new requirement to disclose material cybersecurity incidents on Form 8-K. The SEC’s latest...more

Supreme Court Resolves Circuit Split and Holds ‘Pure Omissions’ Outside Reach of Section 10(b) Liability

On April 12, a unanimous Supreme Court held in Macquarie Infrastructure Corp. v. Moab Partners, L.P. that material omissions are actionable under Section 10(b) of the Exchange Act and its enabling SEC Rule 10b-5 only if the...more

SEC Issues Final Climate Disclosure Rules: Rule’s Future Subject to Challenge

After a 3-2 vote on March 6, 2024, the Securities and Exchange Commission (SEC) adopted final rules for public companies requiring disclosure of climate risk and greenhouse gas emissions. Although scaled back substantially...more

Supreme Court Grants Certiorari to Resolve Circuit Split on Whether SEC Disclosure Rule Triggers Section 10(b) Liability

On Sept. 29, 2023, the U.S. Supreme Court granted certiorari in Macquarie Infrastructure Corp. v. Moab Partners, L.P. to review a decision by the Second Circuit reviving an investor lawsuit alleging Section 10(b) and Rule...more

Investment Adviser Settles SEC Enforcement Action Concerning Alleged Misstatements Regarding ESG Investment Process

On Sept. 25, 2023, the Securities and Exchange Commission announced settled charges against registered investment adviser DWS Investment Management Americas Inc. (DIMA), a Deutsche Bank investment arm, in an enforcement...more

SEC Finalizes New Cybersecurity Disclosure Rules

By a 3-2 vote on July 26, the U.S. Securities and Exchange Commission (SEC) adopted final rules enhancing disclosure requirements regarding public companies’ cybersecurity risk management, strategy, governance and incident...more

SEC Amends Share Repurchase Disclosure Rules

On May 3, 2023, the Securities and Exchange Commission (SEC) adopted amendments to increase disclosures for issuer repurchases of shares or other equity securities that are registered under Section 12 of the Securities...more

Delaware Chancery Court Finds CEO Violated Revlon Duties by Tilting Sale Process to Preferred Bidder and That the Bidder Aided and...

In a recent post-trial decision, Delaware Chancellor Kathaleen St. J. McCormick found a CEO personally liable for breaching his fiduciary duties for tilting the company’s sale to his preferred acquiror. The court further held...more

SEC Announces Enforcement Action for Misleading Non-GAAP Disclosures

The Securities and Exchange Commission (SEC) recently entered into a consent order with IT services company DXC Technology (DXC) with respect to DXC’s alleged violations of the Securities Act and the Exchange Act. The SEC...more

SEC Issues $3 Million Penalty Against Blackbaud for Misleading Cybersecurity Incident Disclosures

On March 9, software company Blackbaud agreed to pay $3 million to the SEC as a result of alleged misleading disclosures arising out of a 2020 data breach that involved customer bank account information and Social Security...more

Corporate Governance: 2022 Year-End Review

Since Kramer Levin issued its Corporate Governance: 2022 Midyear Review, a wave of enforcement actions by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has underscored the continued importance...more

Widespread Disruption in Crypto Markets Prompts New SEC Disclosure Considerations

On Dec. 8, 2022, the Securities and Exchange Commission’s (SEC) Division of Corporate Finance (the Division) posted a sample comment letter (the Letter) on its website that provides guidance to public companies regarding the...more

AT&T and SEC Settle Regulation FD Enforcement Action After SDNY Denies Summary Judgment to Either Side

On Dec. 5, the Securities and Exchange Commission (SEC) announced that AT&T has agreed to a $6.25 million penalty, resolving charges brought against it under the securities rule known as Regulation Fair Disclosure (Regulation...more

SEC Adopts New Conditions and Disclosures Regarding 10b5-1 Plans

On Dec. 14, 2022, the Securities and Exchange Commission (SEC) adopted amendments to Rule 10b5-1, generally in the form issued for comment in January 2022 (replacing the version initially published on Dec. 15, 2021), which we...more

The SEC Adopts Incentive-Based Compensation Clawback Rule

On Oct. 26, the SEC adopted a final rule addressing the obligations of listed issuers or “companies” to recover incentive-based compensation paid to executive officers prior to an accounting restatement. The final rule will...more

Diversity in the Boardroom: A Periodic Litigation and Governance Update

Efforts to increase diversity at the top of public companies remain at the forefront of corporate consciousness and governance. As we have previously reported , stakeholder interest in diversified leadership has led to a...more

Supreme Court Rejects EPA’s ‘Clean Power Plan’ in Decision Raising Questions About the SEC’s Climate-Related Disclosure Rules

On June 30, 2022, the U.S. Supreme Court held in West Virginia v. Environmental Protection Agency, 597 U.S. ___ (2022), that the Clean Air Act did not clearly authorize the Environmental Protection Agency (EPA) to create the...more

The SEC’s Climate and ESG Task Force Charges Vale S.A. With Securities Fraud

On April 28, the Securities and Exchange Commission (SEC) filed a complaint against the Brazilian mining company Vale S.A., alleging that the company made false and misleading statements to investors about the company’s...more

Court Concludes That California Board Diversity Statute Is Unconstitutional

On April 1, 2022, the Superior Court of California, County of Los Angeles, granted a summary judgment motion that effectively struck down AB 979, a California statute requiring the boards of public corporations based in the...more

SEC Proposes Rules to Require New Climate-Related Disclosures

On March 21, 2022, the Securities and Exchange Commission (SEC) issued for comment proposed rules requiring companies to include climate-related disclosures in their registration statements and periodic reports filed under...more

SEC Proposes Comprehensive Cybersecurity Reporting Rules for Public Companies

On March 9, the SEC, by a 3-1 vote, proposed new rules in its most far-reaching effort to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and incident reporting by public...more

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