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Update to SEC Share Repurchase Disclosure Amendments: Fifth Circuit Vacates SEC New Repurchase Rule

On December 19, 2023, the U.S. Court of Appeals for the Fifth Circuit vacated the Securities and Exchange Commission’s (the ​“SEC”) final rule adopting amendments to share repurchase disclosure requirements (US Chamber of...more

SEC Issues Final Rules on Cybersecurity Disclosures

On July 26, 2023, in a 3-2 vote, the Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) for public companies that will require disclosures regarding cybersecurity incidents, as well as...more

SEC Adopts Share Repurchase Disclosure Amendments

On May 3, 2023 the Securities and Exchange Commission (SEC) adopted amendments to modernize the disclosure requirements relating to share repurchases by issuers. The amendments include new tabular disclosures regarding daily...more

SEC Issues Final Rules on Rule 10b5-1 and Insider Reporting Changes

On December 14, 2022, the Securities and Exchange Commission (the “Commission”) adopted final rules (the “Final Rules”) which will affect trading by directors and officers of listed issuers and disclosure about such...more

SEC Adopts Sweeping Pay for Performance Disclosure Requirements for Public Companies

On August 25, 2022, the Securities and Exchange Commission (SEC) adopted rules (the “Final Rules”), which require covered publicly traded companies to provide both tabular and narrative and/or graphical disclosure of the...more

SEC Proposes New Rules on Cybersecurity Disclosures: Four Things to Know

On March 9, the U.S. Securities and Exchange Commission (SEC) announced proposed amendments to its rules regarding cybersecurity disclosures to satisfy a growing investor need to know more about how registrants are managing...more

Congress and SEC Contemplate Modifying 10b5-1 Insider Trading Plans

On June 7, 2021, during prepared remarks delivered at the CFO Network Summit, SEC Chair Gary Gensler announced that he asked SEC Staff to focus closely on reforms to Exchange Act Rule 10b5-1. These reforms would scale back...more

ESG Issues and the SEC: The Dawn of New Realities

There is an ongoing push by the Biden Administration to engrain climate change awareness into many arms of the federal government that were previously agnostic on the matter. This campaign to inject agencies like the...more

Recap of SEC Disclosure Requirements in Response to COVID-19

In this advisory, we recap our guidance for clients in connection with drafting pandemic disclosure for an offering document or evaluating what, if anything, to disclose in public filings. The Securities and Exchange...more

Preparing for Proxy Season: ISS Environmental & Social QualityScore

Background - In February 2018, Institutional Shareholder Services, Inc. (ISS), the largest U.S. proxy advisory firm, announced that an Environmental and Social (E&S) QualityScore Disclosure & Transparency Signal would be...more

SEC Increases Threshold for Qualifying as a Smaller Reporting Company

On June 28, 2018, the Securities and Exchange Commission (SEC) approved amending the definition of “smaller reporting company” (SRC) to increase the financial thresholds for qualification. This change will significantly...more

Dodd-Frank Reform Includes Notable Changes to Rule 701 of the Securities Act and Regulation A+

Introduction - On May 24, 2018, President Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Relief Act”). The Relief Act significantly reforms the Dodd-Frank Wall Street Reform...more

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