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SEC Adopts Final Rules Requiring Section 16(a) Reporting for Directors and Officers of FPIs, and Provides Exemptive Relief for FPI...

On February 27, 2026, the SEC adopted final amendments to its rules and forms under the Exchange Act to implement the HFIA Act. As we discussed in our December 2025 alert, the HFIA Act was enacted on December 18, 2025, as...more

Does AI Care About Caremark? Applying the Core Principles of Corporate Governance to Artificial Intelligence Integration

It started with a routine task: a mid-sized publicly traded company was preparing a quarterly earnings call. An internal team, aiming to streamline the chief executive officer’s (CEO) talking points, employed an artificial...more

Key Issues for Companies and Activist Investors Heading into the 2026 Proxy Season

As the 2026 proxy season prepares to go into full swing, significant structural shifts are underway in the proxy voting ecosystem. Regulatory scrutiny, evolving investor stewardship frameworks and innovations in retail voting...more

Delaware Court of Chancery Rules Workplace Sexual Misconduct Oversight Failures Can Support Shareholder Breach of Fiduciary Duty...

In a precedent-setting derivative decision, the Delaware Court of Chancery held that a board of directors’ and senior officers’ failure to respond in good faith to clear red flags of workplace sexual misconduct may give rise...more

Speaking Sustainability - Legal & Regulatory Updates - January 2026

In a presidential memorandum issued January 7, President Trump announced the United States will begin executive proceedings to withdraw from a historic number of international organizations, conventions and treaties,...more

Speaking Sustainability - Legal & Regulatory Updates - December 2025

The 30th United Nations Climate Change Conference (COP30) ended on November 22, 2025. Among other things, the package of decisions reflected in the Belém Political Package brings renewed focus on scaling up climate finance...more

Section 16(a) Reporting Will Be Required for Foreign Private Issuer Directors and Officers

Starting on March 18, 2026, any executive officer or director of any “foreign private issuer”i (FPI) that has a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the...more

White House Executive Order Targets Proxy Advisory Firms – Potential Implications for Companies and Investors

On December 11, 2025, the White House issued an Executive Order entitled Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors (the “Order”). The Order directs several federal agencies,...more

ISS and Glass Lewis Publish 2026 Benchmark Proxy Voting Policies

Institutional Shareholder Services Inc. (ISS) and Glass Lewis have released their 2026 Benchmark Proxy Voting Policy updates, introducing changes that will impact governance, compensation and shareholder-proposal evaluations...more

Speaking Sustainability - Legal & Regulatory Updates - November 2025

On November 18, the United States Court of Appeals for the Ninth Circuit granted a partial injunction blocking enforcement of California’s climate-related financial risk disclosure law (SB 261). Inaugural reports under SB 261...more

Take No-Action: SEC Will Not Respond to Majority of No-Action Requests During 2026

On November 17, 2025, the U.S. Securities and Exchange Commission’s (SEC) Division of Corporation Finance announced that it will largely stop issuing staff responses to Rule 14a-8 no-action requests for the 2025–26 proxy...more

Glass Lewis to Move Away from a Single “House View”: A New Era in Proxy Advice

In a move that could reshape the proxy voting landscape, Glass Lewis & Co. (Glass Lewis) has announced that it will discontinue its decades-old practice of issuing a single, “house view” recommendation on how institutional...more

Speaking Sustainability - Legal & Regulatory Updates | September 2025

The U.S. District Court for the Western District of Texas entered a preliminary injunction against Texas Senate Bill 2337 (SB 2337) one day before the bill’s effective date. The bill would have regulated proxy advisory firms...more

Speaking Sustainability - Legal & Regulatory Updates | August 2025

Akin’s Speaking Sustainability newsletter provides a monthly digest of key news items and other relevant information on significant legal and regulatory developments in the continuum of sustainability issues, including...more

Glass Lewis Announces Updates to 2026 Pay-for-Performance Model: What Boards and Practitioners Need to Know

Glass Lewis, a leading proxy advisory firm, recently released a preview of changes to its pay-for-performance model that will take effect for the 2026 proxy season. Glass Lewis’ announcement, which is modest in terms of...more

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

Sustainability/ESG Policy and Regulatory Update

Key topics in Akin’s July 2024 Sustainability/ESG Policy and Regulatory Update include: Updated Assessment of SFDR by EU Regulators: The European Supervisory Authorities have proposed changes to the Sustainable Finance...more

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