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SEC Proposes to Expand and Update Accredited Investor and Qualified Institutional Buyer Definitions

The Securities and Exchange Commission (SEC) has approved proposed amendments to the definitions of “accredited investor” and “qualified institutional buyer” (QIB). If approved, the proposed amendments would expand investor...more

SEC Proposes Amendments to Rules on Proxy Voting Advice and Shareholder Proposals

On November 5, 2019, the Securities and Exchange Commission (the SEC) proposed amendments to the proxy rules to improve the accuracy and transparency of proxy voting advice. On the same day, the SEC also proposed amendments...more

"Test-The-Waters" Exemption To Be Available To All Issuers

The Securities and Exchange Commission (SEC) has adopted a new rule that will allow all issuers to engage in test-the-waters communications regarding a contemplated registered securities offering with qualified institutional...more

SEC Issues Guidance Regarding Proxy Voting Process

On August 21, 2019, the Securities and Exchange Commission (the SEC) published two guidance releases regarding the proxy voting process. The first release is guidance to assist investment advisers (or fund managers) who...more

Inline XBRL Interpretations Issued By SEC Staff

The staff of the Division of Corporation Finance of the Securities and Exchange Commission (SEC) has published nine Compliance and Disclosure Interpretations (C&DIs) relating to the Inline XBRL rules adopted in June 2018 and...more

SEC Proposes Round Three Of Disclosure Modernization

The Securities and Exchange Commission (SEC) has proposed a third group of amendments to its disclosure requirements. The proposals would generally simplify disclosure about a company’s business, emphasizing a principlesbased...more

SEC Proposes Universal Access to “Testing-the-Waters” Exemption

The Securities and Exchange Commission (SEC) has announced a proposal to expand the current exemption for “testing-the-waters” communications — currently limited to emerging growth companies (EGCs) — to all companies,...more

Non-GAAP “Equal or Greater Prominence” – SEC Enforcement Action Highlights Importance of Compliance

On December 26, 2018, the Securities and Exchange Commission (SEC) settled enforcement proceedings against ADT Inc. involving certain ADT earnings releases that did not comply with SEC non-GAAP disclosure requirements....more

SEC Adopts Final Hedging Policy Disclosure Rules

The Securities and Exchange Commission (SEC) has adopted final rules that will require companies to disclose any practices or policies regarding the ability of employees and directors to engage in certain hedging transactions...more

ISS Releases 2019 U.S. Voting Policy Updates

In November 2018, Institutional Shareholder Services (ISS) released updates to its 2019 U.S. voting policies, which will be effective for meetings on or after February 1, 2019, and a preliminary list of frequently asked...more

NYSE Updates Smaller Reporting Company Exemption

The New York Stock Exchange (NYSE) has filed an amendment that will change the threshold for exemptions from NYSE compensation committee requirements for smaller reporting companies (SRCs) under Section 303A.00 of the NYSE...more

SEC Issues New Guidance on Shareholder Proposal Exclusions Under “Ordinary Business” and “Economic Relevance” Grounds

The Division of Corporation Finance (Staff) of the Securities and Exchange Commission (SEC) has issued new guidance on the ability of companies to exclude shareholder proposals from their proxy statements under the “ordinary...more

SEC Report Cautions Public Companies on Internal Controls and Cybersecurity Risks

The Securities and Exchange Commission (the Commission) has published a report of an investigation (the Report) into whether certain public companies that suffered financial losses as a result of cyber-related fraud violated...more

Nasdaq Amends Stockholder Approval Rule for Private Placements

The Securities and Exchange Commission has approved the amended Nasdaq proposal to amend Rule 5635(d), which requires Nasdaq-listed companies to obtain shareholder approval before issuing common stock or securities...more

SEC Disclosure Simplification Amendments Effective November 5, 2018

As described in our two earlier client alerts, SEC Adopts First Steps in Disclosure Simplification (September 12, 2018) and SEC Publishes Guidance on Form 10-Q and Disclosure Simplification (October 1, 2018), the Securities...more

SEC Publishes Guidance on Form 10-Q and Disclosure Simplification

Guidance on how the disclosure simplification amendments adopted on August 17, 2018, will affect upcoming Form 10-Q quarterly reports was published by the staff (Staff) of the Securities and Exchange Commission (SEC) Division...more

SEC Adopts First Steps in Disclosure Simplification

After several years and a number of studies and related actions, the Securities and Exchange Commission (SEC) has adopted a series of amendments to its rules and forms that deal with requirements that have become “redundant,...more

SEC Adopts Mandatory Inline XBRL

The Securities and Exchange Commission has amended its eXtensible Business Reporting Language (XBRL) rule to require operating companies to present XBRL financial statement information in “inline” format. Subject to a...more

SEC Expands Smaller Reporting Company Eligibility

The Securities and Exchange Commission (SEC) has adopted amendments that will increase the number of companies eligible to take advantage of the SEC’s reduced, or scaled, disclosure rules as a “smaller reporting company” or...more

NYSE Eliminates Proxy Statement Paper Filing Requirement for Proxy Materials

The Securities and Exchange Commission has approved a New York Stock Exchange proposal to eliminate the requirement to send hard copies of proxy materials to the NYSE if the proxy materials are available on the SEC’s EDGAR...more

Nasdaq Proposes to Amend Stockholder Approval Rule for Private Placements

Nasdaq has proposed to amend Rule 5635(d), which generally requires shareholder approval before Nasdaq-listed companies issue common stock equal to 20% or more of outstanding shares or voting power in transactions (other than...more

SEC Reiterates Cybersecurity Guidance and Provides Color on Disclosure Implications

On February 20, 2018, the Securities and Exchange Commission published Commission Statement and Guidance on Public Company Cybersecurity Disclosures (the “Release”), which states the Commission’s interpretive views on...more

SEC Approves NYSE Non-IPO Listing Amendments

On February 2, 2018, the Securities and Exchange Commission (SEC) approved amendments to the listing standards of the New York Stock Exchange (NYSE) that will permit companies to seek a direct listing of their common equity...more

New PCAOB Audit Standard for Audit Reports

The Public Company Accounting Oversight Board (PCAOB) recently published interpretive guidance on audit reporting standard AS 3101, The Auditor’s Report on an Audit of Financial Statements When the Auditor Expresses an...more

NYSE Dividend Notification Changes Effective February 1

On February 1, 2018, the amendments to the New York Stock Exchange Listed Company Manual adopted in August 2017 become effective. These amendments will require listed companies to notify the NYSE at least 10 minutes before a...more

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