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SEC Expands Accommodations for Issuers Submitting Draft Registration Statements

On March 3, 2025, the staff of the US Securities and Exchange Commission’s Division of Corporation Finance issued an announcement expanding accommodations available for issuers to submit draft registration statements for...more

Prepare Now for Edgar Next

On September 27, 2024, the Securities and Exchange Commission (the "SEC") adopted rule and form amendments to the Commission's Electronic Data Gathering, Analysis, and Retrieval ("EDGAR") system to improve access to and...more

Corp Fin Issues Staff Legal Bulletin 14M

On February 12, 2025, the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance (the “Staff”) issued new guidance that should provide additional leeway for public companies to exclude...more

Key Considerations for the 2025 Annual Reporting Season: Your Upcoming Form 20-F and other FPI-Specific Considerations

With the inauguration of US President Trump on January 20, 2025, public companies await the impact of the new administration on the US Securities and Exchange Commission ("SEC"). President Trump's pick for the next SEC Chair,...more

Key Considerations for Updating 2024 Annual Report Risk Factors

With the 2025 annual reporting season upon us, public companies should consider potential updates to their risk factors for their Form 10-Ks and 20-Fs in light of recent economic, political, technological, and regulatory...more

Key Considerations for the 2025 Annual Reporting and Proxy Season: Your Upcoming Form 10-K

Each year in our Annual Memo, White & Case's Public Company Advisory Group provides practical insights on preparing Annual Reports on Form 10-Ks, Annual Meeting Proxy Statements and, for FPIs, the Annual Report on Form 20-F....more

Insider Trading Policies: A Survey of Recent Filings

White & Case's Public Company Advisory Group has conducted a survey of publicly filed insider trading policies to assess emerging trends with respect to key insider trading policy terms. Starting with Form 10-K/20-F annual...more

SEC Enforcement Heats up on Key Public Company Topics: Cyber Disclosure, Director Independence and Regulation FD

The U.S. Securities and Exchange Commission's ("SEC") Division of Enforcement has recently brought a spate of enforcement actions relating to key topics for public companies. These include enforcement actions related to...more

Judge Rejects SEC’s Aggressive Approach to Cybersecurity Enforcement

On July 18, 2024, a New York federal judge dismissed most of the US Securities and Exchange Commission’s ("SEC") claims against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer...more

Foreign Private Issuers: Don’t Forget to Confirm Your FPI Status!

As we enter the second half of the year, it is once again time for many foreign private issuers (“FPIs”) to complete their annual assessment of FPI status. The determination of whether an issuer is an FPI must be made as of...more

T+1 Settlement Cycle to Take Effect on May 28, 2024

Beginning May 28, 2024, the new T+1 settlement cycle will apply to most routine securities transactions, which means that the settlement period for most securities issuances and trades will shorten from two business days...more

SEC Voluntarily Stays Its Climate Rules Pending Judicial Review

On April 4, 2024, less than one month after their adoption, the U.S. Securities and Exchange Commission ("SEC") has chosen to stay its newly adopted climate disclosure rules, pending judicial review (the "Final Rules"). The...more

SEC Adopts Climate Change Disclosure Rules; Court Imposes Temporary Stay

On March 6, 2024, in a 3 to 2 vote of the Commissioners, the US Securities and Exchange Commission (the "SEC") adopted rules that will require public companies to disclose extensive climate change-related information in their...more

Key Considerations for the 2024 Annual Reporting and Proxy Season Part II: Proxy Statements

Each year in our Annual Memo series, White & Case's Public Company Advisory Group provides practical insights on preparing Annual Reports on Form 10-Ks, Annual Meeting Proxy Statements and, for FPIs, the Annual Report on Form...more

Key Considerations for Updating 2023 Annual Report Risk Factors

With the 2023 annual report season upon us, it is time for companies to take stock of risk factors for 10-Ks and 20-Fs, and consider whether recent economic, political, technological, and regulatory developments have had (or...more

SEC Extends Form 144 Filing Hours

SEC Adopts Amendments to Extend Filing Deadline for Form 144 from 5:30 p.m. to 10:00 p.m. On February 21, 2023, the Securities Exchange Commission (the "SEC") adopted amendments to Regulation S-T to extend the deadline...more

SEC Adopts Move to T+1 Standard Settlement Cycle

SEC Amends Exchange Act Rule 15c6-1 to Require Settlement of Routine Securities Trades in One Business Day Following Trade Date. On February 15, 2023, the Securities and Exchange Commission (the "Commission") adopted a...more

PCAOB and Chinese Authorities Sign Agreement, Taking First Step Toward Complete Access for PCAOB to Inspect and Investigate...

On August 26, 2022, the US Public Company Accounting Oversight Board (the "PCAOB") signed a Statement of Protocol (the "SOP") with the China Securities Regulatory Commission (the "CSRC") and the Ministry of Finance of the...more

SEC Proposes Rules to Regulate SPACs

On March 30, 2022, the US Securities and Exchange Commission (the "SEC"), in a three-to-one vote of its commissioners divided along political lines, approved the issuance of proposed rules regarding special purpose...more

A rollercoaster year for SPACs

After a flurry of new listings in the first quarter of 2021, SPAC IPOs slowed down considerably, but the asset class remains a viable path for companies to go public - Special purpose acquisition companies (SPACs) had a...more

SEC Posts Sample Letter to China-Based Companies, Amid a Stalled Process for SEC Clearance of their Offerings

On December 20, 2021, the SEC's Division of Corporation Finance (the "Division") posted an illustrative letter containing sample comments that the Division may issue to companies based in, or with the majority of their...more

ISS and Glass Lewis Issue 2022 Updates: Top Six Key Policy Changes and Take-Aways

In the past few weeks, both major proxy advisory firms, Institutional Shareholder Services ("ISS") and Glass Lewis & Co. LLC ("Glass Lewis"), have issued their updated proxy voting guidelines for the 2022 proxy season. These...more

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