Like a fashion trend that never fails to come back in style (we look fabulous in baggy jeans, btw), we're revisiting SEC enforcement actions involving public company executive perquisites – or "perks" – a topic we have...more
1/31/2025
/ Cooperation ,
Corporate Governance ,
Disclosure Requirements ,
Employee Benefits ,
Enforcement Actions ,
Executive Compensation ,
Perks ,
Publicly-Traded Companies ,
Regulation S-K ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Settlement
2024 saw no change in the government's campaign to encourage self-reporting and cooperation. In the second installment of Season's Readings, we take a quick look at how the SEC treats self-reporting and how that differs...more
In recent remarks at the Securities Enforcement Forum West 2024, U.S. Securities and Exchange Commission (SEC) Director of the Division of Enforcement Gurbir Grewal extolled the benefits of and expounded on the elements of...more
Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more
11/17/2023
/ Administrative Proceedings ,
Civil Monetary Penalty ,
Cooperation ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Internal Investigations ,
Non-Prosecution Agreements ,
Publicly-Traded Companies ,
Remediation ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Voluntary Disclosure
We return once more to the issue of public company executive perquisites or "perks" – a topic we anticipated last year would "be a hot-button enforcement issue for the foreseeable future." We were not wrong. In light of the...more
7/11/2023
/ Compensation & Benefits ,
Cooperation ,
Corporate Governance ,
Enforcement Actions ,
Executive Compensation ,
Failure To Disclose ,
Perks ,
Publicly-Traded Companies ,
Regulatory Violations ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Self-Reporting
Earlier this month at the Securities Enforcement Forum West, SEC Director of Enforcement Gurbir Grewal offered some plainspoken advice to the defense bar: Stop delaying investigations and help build the public's trust in the...more