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Developments in Crypto Regulation: DeFi Tax Reporting Repeal and SEC Disclosure Guidance

The Trump administration continues its efforts to relax digital asset regulation, including most recently by exempting decentralized finance ("DeFi") apps and wallets from tax reporting and through Securities and Exchange...more

SEC Chair Warns Against "AI Washing"

As public companies increasingly discuss their artificial intelligence ("AI") capabilities, the U.S. Securities and Exchange Commission ("SEC") reminds us that it is closely watching these claims....more

SEC Adopts Amendments to the Beneficial Ownership Rules

In Short - The Background: On October 10, 2023, the U.S. Securities and Exchange Commission (the "SEC") adopted amendments to the rules that govern beneficial ownership reporting for investors, marking the first update to...more

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

In Short - The Situation: On July 26, 2023, the U.S. Securities and Exchange Commission ("SEC") adopted final rules that significantly alter cybersecurity disclosure obligations for companies. The SEC's final rules adopt...more

SEC Advances Three Cybersecurity Rule Proposals to Public Comment

If adopted, these proposed rules would (i) enhance protection of customer information under Regulation S-P, (ii) add new requirements addressing cybersecurity risk to the U.S. securities markets, and (iii) expand the types of...more

SEC Adopts Final Rules Regarding Rule 10b5-1 Trading Plans and Related Disclosures

In Short - The Situation: On December 14, 2022, the Securities and Exchange Commission ("SEC") adopted final rules that significantly alter the ways in which directors and officers adopt and utilize Rule 10b5-1 plans and...more

U.S. and Chinese Regulators Sign Agreement on Access to Audit Materials

In Short - The Situation: The U.S. Public Company Accounting Oversight Board's ("PCAOB") ability to inspect and investigate PCAOB-registered public accounting firms in mainland China and Hong Kong was previously restricted...more

SEC Climate Rules Will Significantly Impact Foreign Private Issuers

As discussed in Jones Day's March 2022 Alert, the SEC has proposed climate-related disclosure rules. If adopted as proposed, the Proposed Rules would depart from the SEC's historical regulation of SEC-reporting FPIs, which...more

The SEC's New Proposed SPAC Rules: Death Knell or Much-Needed Guidance?

In 2020 and the first quarter of 2021, the use of special purpose acquisition companies ("SPACs") as a means of taking companies public grew exponentially. SPAC IPOs raised a total of more than $160 billion in that five...more

SEC Proposes Amendments Regarding Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

As part of the SEC's broader rulemaking initiative, on March 9, 2022, the SEC proposed amendments to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

SEC Reviews and Approves NYSE Rule Changes to Permit Capital Raising in Direct Listings

The Situation: In August 2020, the Division of Trading and Markets ("Division") of the U.S. Securities and Exchange Commission ("SEC") approved proposed rule changes by the New York Stock Exchange ("NYSE") to permit primary...more

SEC Expands Accredited Investor and Qualified Institutional Buyer Categories

The Situation: The term "accredited investor" under the Securities Act of 1933 ("Securities Act") is used to establish the eligibility of investors to participate in offerings conducted under the most frequently used private...more

The Holding Foreign Companies Accountable Act and Related Nasdaq Proposed Rule Changes

Recent measures from U.S. lawmakers and Nasdaq to impose additional requirements on U.S.-listed China-based companies could have wider implications. On May 20, 2020, the U.S. Senate unanimously passed the Holding Foreign...more

NYSE Reproposes to Permit Capital Raising in Direct Listings - Following two prior proposals during 2019, the New York Stock...

The current proposal, which was submitted by the NYSE on June 22, 2020, would, like the prior proposal, allow a private company seeking to raise capital through a direct listing to satisfy the NYSE's market value requirement...more

COVID-19-Related Disclosure Considerations for Upcoming Periodic SEC Reporting

The ongoing COVID-19 pandemic has resulted in unprecedented and rapidly evolving disruptions to public companies’ businesses, financial condition, and results of operations, as well as broad-based economic dislocation and...more

SEC Proposes Amendments to Modernize and Enhance Financial Disclosures

The Situation: In an effort to modernize, simplify, and enhance certain financial disclosure requirements in Regulation S-K, the U.S. Securities and Exchange Commission ("SEC") proposed certain amendments on January 30,...more

NYSE Proposes Updated Rule Change to Permit Capital Raising in Direct Listings

Less than a week after the U.S. Securities and Exchange Commission ("SEC") rejected a proposed rule change to permit primary capital raising in direct listings, the New York Stock Exchange ("NYSE") submitted an updated...more

SEC Rejects Initial NYSE Proposal on Capital Raising in Direct Listings - The rule change would have allowed companies to raise...

On December 6, 2019, the U.S. Securities and Exchange Commission rejected a proposed New York Stock Exchange ("NYSE") rule change that would allow companies to raise capital in a direct listing...more

NYSE Proposes a Capital-Raising Option in Direct Listings

The Situation: Direct listings, through which a company lists its shares on a national stock exchange without conducting a traditional initial public offering ("IPO"), have received significant attention from the media and...more

SEC Qualifies First Issuance of Digital Token Under Regulation A+

The Situation: As the U.S. Securities and Exchange Commission ("SEC") continues to bring enforcement actions to stop unregistered sales of digital tokens, blockchain companies are exploring ways to sell tokens to the public...more

SEC Explores Ways to Simplify, Harmonize, and Improve the Framework For Exempt Offerings

The Situation: In recent years, the overall framework for exempt offerings has shifted as new exemptions from the registration requirements of the Securities Act of 1933 ("Securities Act") have been introduced and existing...more

SEC Provides Framework to Determine if Digital Assets are Securities

The Situation: The Director of the U.S. Securities and Exchange Commission's Division of Corporate Finance, William Hinman, has weighed in on when digital assets will be characterized as securities. The Result: In...more

Blockchain for Business

As the interest in blockchain technology grows, companies will be confronted with numerous decisions, challenges, and legal issues pertaining to its adoption. Relevant matters include the overall design and control of...more

Delaware Becomes the First State to Allow Corporations to Maintain Corporate Records Using Blockchain Technology

On August 1, 2017, Delaware became the first state to allow corporations to use blockchain technology to maintain corporate records. This development comes almost a year after Vice Chancellor J. Travis Laster of the Delaware...more

SEC's Investigative Report Raises Difficult Questions for ICO Issuers

Against the backdrop of recent growth of initial coin or token offerings ("ICOs"), the U.S. Securities and Exchange Commission ("SEC"), on July 25, 2017, published its first public statements on this fundraising practice. The...more

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