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Making Waves No Longer: SEC Abandons Climate Disclosure Rule

In a widely anticipated move, the U.S. Securities and Exchange Commission (SEC) has announced that it will no longer defend the agency’s climate disclosure rule issued during the Biden administration. The disclosure rule...more

SEC Staff Issues Guidance on Effectiveness of Form S-3 After Filing Form 10-K but Prior to Filing Part III Information

On March 20, 2025, the U.S. Securities and Exchange Commission (SEC) staff issued a set of Compliance & Disclosure Interpretations (C&DIs). In particular, SEC staff revised or withdrew several C&DIs to allow all Form S-3s,...more

SEC Staff Provides Guidance on Private Offerings to Accredited Investors That Permit General Solicitation and Other Exemptions

On March 12, 2025, the U.S. Securities and Exchange Commission (SEC)’s Division of Corporation Finance (SEC Staff) published new and revised Compliance and Disclosure Interpretations (C&DIs) regarding private offering...more

SEC Publishes Revised C&DI Related to Lock-Up Agreements in Business Combinations and New C&DIs Related to Tender Offers

On March 6, 2025, the U.S. Securities and Exchange Commission (SEC) published (1) a revised Compliance and Disclosure Interpretation (C&DI) regarding lock-up agreements in business combinations and (2) five new C&DIs...more

SEC Announces Measures to Facilitate Capital Formation

In March 2025, the U.S. Securities and Exchange Commission (SEC) announced that it is expanding the accommodations available for issuers that submit draft registration statements for nonpublic review. The SEC’s Division of...more

SEC Seeks to Pause Litigation Over Climate Disclosure Rule

Earlier this week, Mark Uyeda, the Acting Chairman of the U.S. Securities and Exchange Commission (SEC), began the process of unwinding that agency’s final climate disclosure rule enacted during the Biden administration. In a...more

ISS Indefinitely Halts Consideration of Diversity Factors When Making Proxy Voting Recommendations

On February 11, 2025, Institutional Shareholder Services (ISS) announced that it is suspending the consideration of diversity factors when making voting recommendations for directors at U.S. public companies. ISS’s press...more

ISS, Glass Lewis and BlackRock Issue 2025 Voting Guidelines

As companies begin preparing for the 2025 proxy season, Institutional Shareholder Services Inc. (ISS) and Glass Lewis, the leading providers of corporate governance solutions and proxy advisory services, recently issued...more

Nasdaq Diversity Rule Deemed Unenforceable By 5th Circuit

On December 11, 2024, the U.S. Court of Appeals for the 5th Circuit, sitting en banc, ruled that The Nasdaq Stock Market LLC (Nasdaq) cannot enforce previously adopted listing rules requiring Nasdaq-listed companies to have...more

SEC Publishes Five C&DIs Covering Cybersecurity Incident Disclosures Pursuant to Item 1.05 of Form 8-K

On June 24, 2024, the U.S. Securities and Exchange Commission (SEC) published five new Form 8-K Compliance and Disclosure Interpretations (C&DIs) expanding the agency’s interpretations of cybersecurity incident disclosures...more

SCOTUS Ruling: Pure Omissions Are Not Actionable Under Rule 10b-5

On April 12, 2024, the U.S. Supreme Court issued an important decision in the case of Macquarie Infrastructure Corp. v. Moab Partners, L.P., No. 22-1165. Justice Sotomayor, writing for a unanimous Court, ruled that “pure...more

Making Waves: The SEC Publishes Final Climate Disclosure Rules

Key Points - On Wednesday, March 6, 2024, the SEC in a 3-2 vote adopted “The Enhancement and Standardization of Climate-Related Disclosures for Investors” (Final Rule). The Final Rule will require public companies to...more

SEC Adopts Final Rules on SPACs, Shell Companies and Projections

The Securities and Exchange Commission (SEC) recently adopted final rules (available here; also see the fact sheet and press release) representing significant changes to  special purpose acquisition companies (SPACs), shell...more

SEC Adopts Final Rules on Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure by Public Companies

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted final rules that generally require public companies to disclose (i) material cybersecurity incidents within four business days after determining the...more

New SEC C&DIs Relating to Rule 10b5-1 Amendments

As discussed in our prior publication (found here), the Securities and Exchange Commission (SEC) adopted amendments on December 14, 2022, regarding Rule 10b5-1 insider trading plans and related disclosures. On May 25, 2023,...more

SEC Adopts Amendments Regarding Share Repurchase Disclosure

On May 3, 2023, the Securities and Exchange Commission (SEC) adopted amendments requiring disclosure related to issuers’ share repurchases. Item 703 of Regulation S-K currently requires issuers to disclose information about...more

Landmark SEC and DOJ Insider Trading Cases Signal Increased Scrutiny of Rule 10b5-1 Plans

Key Points - On March 1, 2023, the SEC and DOJ filed insider trading charges against a public company executive alleging he traded pursuant to 10b5-1 trading plans he adopted while he was in possession of material...more

Proxy Advisory Firms Issue 2023 Voting Guidelines

As companies begin preparing for the 2023 proxy season, we note that Institutional Shareholder Services Inc. (ISS) and Glass Lewis, the leading providers of corporate governance solutions and proxy advisory services, issued...more

SEC Amendments Regarding Rule 10b5-1 Insider Trading Plans and Related Disclosures

On December 14, 2022, the Securities and Exchange Commission (SEC) adopted amendments regarding Rule 10b5-1 insider trading plans and related disclosures. The amendments aim to strengthen investor protections concerning...more

SEC Adopts Final Clawback Rules

On October 26, 2022, the U.S. Securities and Exchange Commission (SEC) adopted long-awaited final rules implementing the “clawback” provisions of Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act....more

Sea Change: The SEC Makes Waves with New Proposed Climate Disclosure Rules

Key Points - On Monday, March 21, 2022, the SEC in a 3-1 vote proposed amendments to require public companies to provide certain climate-related information in their registration statements and annual reports. The...more

Disclosing Cyber Incidents and Risks: SEC Proposes Rules to Enhance and Standardize Cyber Disclosures and Incident Reporting by...

Key Points - Proposed amendments bolster cyber disclosure and incident reporting requirements to better inform investors about a company’s risk management, strategy and governance relative to cyber issues. Under the...more

SEC Proposes Rules to Enhance and Standardize Cyber Disclosures and Incident Reporting by Public Companies

Key Points - Proposed amendments bolster cyber disclosure and incident reporting requirements to better inform investors about a company’s risk management, strategy and governance relative to cyber issues. ...more

New Proposed Rules Affecting 10b5-1 Trading Plans and Share Repurchase Programs

On December 15, 2021, the SEC proposed amendments regarding Rule 10b5-1 trading plans and share repurchase programs. The SEC proposed rules are intended to diminish information asymmetry between public companies and investors...more

SEC Chair Gensler Warns of a New Era of Cyber-Securities Laws

Gary Gensler, Chair of the U.S. Securities and Exchange Commission (SEC), signaled a new era of cybersecurity law (and accompanying enforcement) in his keynote address “Cybersecurity and Securities Laws” on January 24, 2022,...more

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