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Revisiting Stock Option Repricing

Equity-based incentives are intended to motivate high levels of performance and align the interests of employees with those of shareholders. When markets decline steeply, however, many companies find that a significant...more

COVID-19: Disclosure and Capital Markets Considerations for US Listed Public Companies

COVID-19: DISCLOSURE AND CAPITAL MARKETS CONSIDERATIONS FOR US LISTED PUBLIC COMPANIES - The outbreak and continuing spread of the novel coronavirus (“COVID-19”) and the related disruption to the worldwide economy are...more

The Impact of COVID-19 on Incentive Compensation

The COVID-19 outbreak has had a swift and volatile impact on business operations and the financial markets. Because this is occurring simultaneously with the annual incentive award cycle of many companies, immediately at...more

New York State Requires Companies to Report on Number of Women Corporate Board Directors

On December 30, 2019, New York State enacted the “Women on Corporate Boards Study Act” (the “Act”), which requires the New York Department of State and the Department of Taxation and Finance to conduct a study on the number...more

IRS Issues 162(m) Proposed Regulations

On December 16, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code (the “Proposed Regulations”). The Proposed Regulations respond to comments made on Notice 2018-68 (the “Notice”),...more

California Codifies Employee Classification Standards

On September 10, 2019, the California State Senate passed Assembly Bill 5 (AB 5) effectively requiring certain workers previously operating as independent contractors to be considered employees. Governor Gavin Newsom is...more

Hot Topics: Dodd-Frank Act Hedging Policy Disclosures Begin

Although final rules were published in December of 2018, July 1st marked the date that issuers (other than smaller reporting companies and emerging growth companies) must begin complying with the Dodd-Frank Act’s hedging...more

NY Toughens Sexual Harassment and Discrimination Laws

On June 19, 2019, the New York State Assembly and Senate passed an omnibus bill (A08421/S06577) proposing sweeping amendments to existing state sexual harassment and discrimination laws. The pending law, which has the...more

New Year, New Rules: Arrival of the Final Hedging Disclosure Rules

On December 18, 2018, the Securities and Exchange Commission (SEC) approved long-awaited final rules implementing Section 955 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Consistent with the proposed...more

2019 Proxy Season – Quick Reference Guide

’Tis the season, and no, we do not mean the holiday season. Although it may seem like you just filed your 2018 proxy, the 2019 proxy season is upon us. This quick reference guide, which is intended to supplement Shearman &...more

SEC Issues Final Rules to Increase Rule 701 Enhanced Disclosure Threshold

Publishes Concept Release to Explore Rule 701 and Form S-8 Reform - The Adopting Release - On June 18, 2018, the Securities and Exchange Commission (SEC) issued final rules to amend Securities Act Rule 701, which...more

Hot Topics: Enforceability Of Arbitration Provisions In Employment Agreements

On May 21, 2018, in a 5-4 decision, the United States Supreme Court held, in Epic Systems Corp. v. Lewis, that arbitration clauses in employment contracts requiring individualized proceedings are enforceable and thereby...more

Rule 701 Enhanced Disclosure Threshold to Increase

On May 24, 2018, President Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (Reform Act). Although largely focused on regulatory exemptions for smaller financial institutions, the...more

Hot Topics: Focus on the Gender Pay Gap

Recently, the gender pay gap has become the subject of increased scrutiny and media attention as a growing movement works to bring an end to gender-based wage differentials. On April 9, 2018, there was an interesting...more

Delaware Supreme Court Limits Stockholder Ratification Defense for Director Compensation Decisions

Last week, the Delaware Supreme Court, in In re Investors Bancorp, Inc. Stockholder Litigation (“Bancorp”), reversed the Delaware Court of Chancery and held that awards granted to directors under a stockholder-approved equity...more

Tax Cuts and Jobs Act: House and Senate Pass Tax Reform Bill

On December 19, 2017, the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Bill”). The House of Representatives passed the Bill on December 20, 2017. This follows the release by the conference committee of the...more

2018 Proxy Season – Quick Reference Guide

Death, taxes and proxy season. Although it may seem like you just filed your 2017 proxy, the 2018 proxy season is on the horizon. This quick reference guide identifies considerations based on themes from 2017, offers...more

House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

The Republican Tax Plan and the Revenue-Raising Assault on Employee Compensation

On November 2, 2017, the Republican caucus of the House of Representatives unveiled its plan to overhaul the nation’s tax code. In an apparent effort to raise revenue, the “Tax Cuts and Jobs Act,” if adopted, would...more

SEC Staff Gives Company Boards Central Role in 14a-8 ‘Ordinary Business’ and ‘Economic Relevance’ Exclusions

On November 1, 2017, the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (SEC) issued Staff Legal Bulletin No. 14I (SLB 14I) on shareholder proposals, which sets out a...more

SEC Issues Pay Ratio Guidance

With the first required pay ratio disclosures only a few months away, the Commission, on September 21, 2017, issued an interpretative release intended to assist registrants in their compliance efforts. The guidance in the...more

DOL Seeks Further Delay of ‘Fiduciary Rule’ Exemptions

On August 9, 2017, the Department of Labor notified the District Court of Minnesota that it had submitted to the Office of Management and Budget amendments that would delay until July 1, 2019 the applicability of three...more

CHOICE Act 2.0 Passes the House: What Is the ‘CHOICE’?

On June 8, 2017, the House of Representatives passed an amended version of H.R. 10, the Financial CHOICE Act of 2017, or CHOICE Act 2.0, which scales back or eliminates many of the post-crisis financial reforms that were...more

DOL Announces No Further Delay to Implementation of the ‘Fiduciary Rule’

On May 22, 2017, Secretary of Labor Alexander Acosta announced that the DOL has found no “principled legal basis” to further delay the June 9, 2017 applicability date of its “fiduciary rule.”...more

DOL Finalizes 60-Day Delay of ‘Fiduciary Rule’

On April 4, 2017, the Department of Labor issued a final rule delaying the applicability date of its “fiduciary rule” and related exemptions to June 9, 2017. The delay also provides that (1) reliance on the Best Interest...more

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