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SPACs: Delaware Opts Out of “Untold Chaos”

Possibly regretting the repercussions of its recent decision in Delman v. GigAcquisitions3, the Delaware Court of Chancery opted on February 21, 2023, to restore relative peace to dozens of SPACs for which the capital...more

Earnings Management Red Flags: Part Two

In part one of this two-part series, I reviewed what earnings management is (and isn’t) and went through a few examples of earnings-management-related actions brought by the Securities and Exchange Commission (SEC). In this...more

Earnings Management Red Flags: Part One

Public companies are under tremendous pressure to meet or beat stock analyst earnings estimates. This pressure caused Warren Buffet to observe: “Managers that always promise to ‘make the numbers’ will at some point be tempted...more

OFAC Sanctions: Avoiding Unintentional Violations

Are you a US-headquartered company with international business operations? How confident are you that your company and its agents, employees, affiliates, or subsidiaries are not dealing with foreign countries, geographic...more

Peloton’s Pledging Policy: Feeling the Burn

Fewer public companies are allowing insiders, including directors and officers, to hedge and/or pledge their shares. These days, insider trading policies will typically include a section covering these practices and either...more

Personal Liability Protection: A Simple Guide for Directors and Officers

As a director or officer of a public or private company, you need to have strong protections in place to reduce your exposure to personal liability, as well as appropriately respond in case you become subject to an...more

New Director Onboarding: A Roadmap for Boards

Public company boards face an ever-increasing list of topics that fall under their oversight responsibilities. As the list gets longer, so too does the breadth of skills and backgrounds that boards view as important when...more

SEC Adopts Amendments to Its Own Rules Regulating Proxy Advisory Firms

Proxy advisory services have been beset by controversy. In response, in July 2020, the Securities and Exchange Commission (SEC) issued final rules (the 2020 Final Rules) tightening regulations that govern proxy advisory...more

Outside Director Communications: Maximizing the Potential to Protect Attorney-Client Privilege

Email communications can be a trap for unwary independent directors. The December 2020 In re WeWork Litigation decision illustrates the point, as discussed in this earlier blog. Specifically, directors who often use corporate...more

Forward-Looking Statements Disclaimers: Practical Advice for Management Teams and Companies

Forward-looking statements⁠—statements that evidence management’s beliefs about what the future holds—can be valuable to analysts and investors. They are also very interesting to plaintiffs’ attorneys, especially if those...more

Governance Disclosure and the SEC’s Proposed Climate Rules

On March 21, 2022, the Securities and Exchange Commission (“SEC”) proposed rule amendments (the “Proposed Rules”) that would require most US public companies and foreign private issuers to include certain climate-related...more

Multinational Companies and Local Foreign D&O Liability Insurance

Multinationals continue to find themselves subject to expanding laws and regulations across the world. Add to this the heightened frequency of cross-border cooperation between regulators and you have a recipe for increased...more

Practical Guidance for Responding to a Potential Regulation FD Disclosure Issue

Sometimes it turns out that an authorized speaker for your public company (e.g., CEO, CFO, or head of investor relations) has selectively shared nonpublic information with analysts or investors that he or she thought was...more

Implementing a Corporate Social Media Policy

Directors and officers know that social media is a megaphone—but do they know who at the company is holding the megaphone? And are any guardrails in place? In this week’s D&O Notebook, my colleague Lenin Lopez provides timely...more

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