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First Circuit Reverses SEC Win in $93 Million Investment Adviser Disclosure Case

The court rejects the SEC's per se materiality argument and requires proof of a causal connection between the defendant's allegedly inadequate disclosures and purported unlawful profits....more

SEC Revises Guidance Affecting Shareholder Activism Under SLB No. 14M and C&DIs

On February 12, 2025, the U.S. Securities and Exchange Commission's ("SEC") Division of Corporation Finance published Staff Legal Bulletin No. 14M ("SLB 14M") relating to the application of the shareholder proposal rules and...more

SEC Signals It Will Abandon Defense of Climate Disclosure Rule

Acting Securities and Exchange Commission ("SEC" or the "Commission") Chairman Mark Uyeda directed SEC staff to request that the Eighth Circuit Court of Appeals not schedule an oral argument in the pending litigation...more

SEC Settles Charges with Keurig Over ESG Disclosures

On September 10, 2024, the SEC settled charges against Keurig for "incomplete and inaccurate" ESG disclosures about the recyclability of Keurig's K-Cup pods, signaling a continued focus on environmental-related disclosures...more

SEC v. SolarWinds: Court Rejects SEC Authority Over Cybersecurity Controls and Most Alleged Disclosure Violations

The U.S. District Court for the Southern District of New York dismissed the majority of claims that the Security and Exchange Commission ("SEC") asserted against SolarWinds, including claims that the company's alleged...more

SEC Enforcement in Financial Reporting and Disclosure: 2023 Year-End Update

We are pleased to present our latest update on financial reporting and issuer disclosure enforcement activity. This White Paper primarily focuses on the U.S. Securities and Exchange Commission’s (“SEC”) enforcement activity...more

SEC Enforcement in Financial Reporting and Disclosure: Summer 2023 Update

We are pleased to present our latest update on financial reporting and issuer disclosure enforcement activity. This White Paper primarily focuses on the U.S. Securities and Exchange Commission’s (“SEC”) enforcement activity...more

SEC Fines Company $3 Million for Allegedly Misleading Cyberattack Disclosures

Asserting that the company misstated the scope of data stolen in the cyberattack, the SEC provides a clear reminder that cybersecurity disclosures remain an agency priority....more

SEC Enforcement in Financial Reporting and Disclosure: 2022 Year-End Update

We are pleased to present our latest update on financial reporting and issuer disclosure enforcement activity. This White Paper primarily focuses on the U.S. Securities and Exchange Commission's ("SEC") enforcement activity...more

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