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What’s the Deal? – Stock Repurchase Programs: Useful Reminders

As the pandemic has taken hold, there has been a predictable decline in stock repurchase activity; however, many issuers are evaluating restarting their programs or undertaking new programs.  In this What’s the Deal guide, we...more

Proposed Changes to NYSE Shareholder Approval Rules

On October 6, 2020, the New York Stock Exchange (“NYSE”) filed a proposed rule amendment in order to seek approval to amend certain of the shareholder approval requirements set forth in Section 312 of the NYSE Listed Company...more

BDCs Benefit from the SEC’s New Fund of Funds Rule

On October 7, 2020, the Securities and Exchange Commission (“SEC”) adopted a new rule designed to streamline and enhance the regulatory framework for funds that invest in other funds (“fund of funds arrangements”).  The new...more

SEC Approves Further Extension of NYSE’s Relief from Shareholder Approval Rule

On September 28, 2020, the US Securities and Exchange Commission (“SEC”) approved, with immediate effectiveness, the New York Stock Exchange’s (“NYSE”) proposal to further extend its waiver of the shareholder approval...more

Issuers Permitted to Raise Capital in Direct Listings

On August 26, 2020, the Securities and Exchange Commission (the “SEC”) approved the proposal submitted by the New York Stock Exchange (“NYSE”) that allows companies to conduct concurrent primary offerings as part of a direct...more

What’s the Deal? – 10b5-1 Plans

Here’s the deal: A Rule 10b5-1 plan is a written securities trading plan that is designed to comply with Rule 10b5-1(c) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). ...more

What’s the Deal? – Shelf Registration Statements and Shelf Takedowns

Here’s the deal: An effective shelf registration statement allows an issuer to be in a position to complete multiple offerings from time to time in the future without having the timing of any such offering delayed by a...more

What's the Deal? - ATM Offerings

An “at-the-market” (“ATM”) offering is an offering of securities into an existing trading market for the securities at a price or prices related to the then-market price of the securities. ATM offerings are continuous...more

NYSE Amends Proposal to Allow Issuers to Raise Capital in Direct Listings

On June 22, 2020, the New York Stock Exchange (“NYSE”) submitted an amended proposal to the Securities and Exchange Commission (“SEC”) that would modify existing NYSE rules relating to direct listings in order to permit...more

SEC Staff Eases Paper Filing Requirements Due to COVID-19

On June 25, 2020, the staff of the Division of Corporation Finance (the “Staff”) released three temporary statements to assist filers impacted by the COVID-19 pandemic....more

Consider Form S-3 Eligibility if Preferred Dividends are Delayed

Some issuers have suspended dividend payments on outstanding preferred stock as a result of COVID-19 pandemic-related economic concerns. In order to remain eligible to use a Form S-3 registration statement, among other...more

SEC Approves NYSE’s Temporary Relief from Shareholder Approval Rule

On May 14, 2020, the Securities and Exchange Commission (“SEC”) approved, with immediate effectiveness, a rule filing from the New York Stock Exchange (“NYSE”) granting temporary relief from the shareholder approval...more

SEC Extends EDGAR Window for RICs and BDCs

In order to mitigate potential filing delays due to the ongoing impacts of the COVID-19 pandemic, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management has extended the EDGAR filing window from...more

SEC Approves Nasdaq’s Tolling of Compliance Period

On April 17, 2020, the Securities and Exchange Commission (“SEC”) approved, with immediate effectiveness, the proposal filed by The Nasdaq Stock Market (“Nasdaq”) to permit a longer period of time for Nasdaq-listed companies...more

SEC Approves NYSE’s Temporary Relief for Listed Companies

On April 6, 2020, the Securities and Exchange Commission (“SEC”) approved, with immediate effectiveness, the proposal filed by the New York Stock Exchange (“NYSE”) with the Commission on April 3, 2020 to waive certain...more

WKSIs Should Verify their Status in Light of Recent Market Downturn

The COVID-19 pandemic has resulted in severe market volatility in U.S. capital markets and the loss of significant equity value for many U.S. public companies.  As a result, many companies may be at risk of losing their...more

Legal Update: Proposed Amendments to the Accredited Investor Definition

On December 18, 2019, the Securities and Exchange Commission (“SEC”) proposed amendments to the definition of “accredited investor” and related amendments to the definition of “qualified institutional buyer.” The proposed...more

SEC Rejects NYSE Proposal to Allow Fundraising in Direct Listings

On December 6, 2019, the Securities and Exchange Commission (“SEC”) rejected the proposal submitted by the New York Stock Exchange (“NYSE”) to allow companies to simultaneously go public through a direct listing and raise...more

SEC Clarifies BDC Repurchase Obligation

On October 17, 2019, the Staff of the Division of Investment Management released FAQs meant to assist business development companies (“BDCs”) that have obtained the requisite approvals for lowering their asset coverage from...more

SEC Clarifies Application of Securities Laws to OZ Funds

On July 15, 2019, the staffs of the Securities and Exchange Commission (“SEC”) and the North American Securities Administrators Association issued a joint summary explaining the application of the federal and state securities...more

FINRA Proposes Changes to its Fund Communication Rules

On June 20, 2019, the Financial Industry Regulatory Authority, Inc. (“FINRA”) proposed amendments to FINRA Rule 2210 (Communications with the Public) and FINRA Rule 2241 (Research Analysts and Research Reports) to further the...more

SEC Loosens In-Person Voting Requirement for BDC Boards

On February 28, 2019, the staff of the Securities and Exchange Commission’s Division of Investment Management issued a no-action letter to the Independent Directors Council permitting board members of a business development...more

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