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Change on the Way: SEC Reiterates Commitment to Disclose Reform

Last week, James Moloney, Director of the SEC’s Division of Corporation Finance, released a statement reiterating the Division’s general commitment to disclosure reform on an expedited timeline. Classifying these potential...more

SEC and Large Banks Continue Pushback on Proxy Advisers After JPMorgan

The Wall Street Journal is reporting that Wells Fargo has adjusted its approach to proxy voting and its use of proxy-advisory services, adding another high‑profile example to the growing trend of large financial institutions...more

Key Themes from the 2026 J.P. Morgan Healthcare Conference: Evidence, Execution and Emerging Momentum

Coming off the expectations we outlined in our J.P. Morgan Healthcare Conference Preview, this year’s conference in San Francisco largely delivered on its promise: acceleration with structure, renewed dealmaking confidence,...more

2026 J.P. Morgan Healthcare Conference Preview: Dealmaking, Capital, and Strategic Themes to Watch

Heading into the J.P. Morgan Healthcare Conference, the conversation will center on accelerated deal flow, selective but improving capital access, and disciplined execution. Strategic buyers face patent cliffs and pipeline...more

JPMorgan’s Split With Proxy Advisers: A Harbinger For The 2026 Proxy Season

In an industry-first move, the Wall Street Journal reports that JPMorgan Chase’s asset‑management arm has cut all ties with the major proxy advisory firms, effective immediately, according to an internal memo cited by the...more

White House Weighing Limits on Proxy Advisers and Index-Fund Voting

As reported by the Wall Street Journal, the White House is considering executive actions that would restrict the influence of proxy advisory firms and index-fund managers. According to the Wall Street Journal, the measures...more

SEC Issues Concept Release Soliciting Public Comment on Foreign Private Issuer Definition

On June 4, 2025, the SEC issued a concept release soliciting public comment on the definition of “foreign private issuer” (FPI) under U.S. securities laws. The SEC has identified potential changes to the definition that could...more

SEC Issues New C&DIs re: Compensation Clawback Disclosures and De-SPACs

On April 11, 2025, the Division of Corporation Finance issued new compliance and disclosure interpretations (C&DIs), six of which relate to executive compensation clawback disclosures and one of which relates to the...more

Congress Considering Securities Offering Reform to Encourage Capital Formation

On Tuesday, March 5th, the U.S. House Financial Services Committee debated several bills that could have a significant impact on capital formation in private and public markets. The bills reflect the ongoing push for...more

2024 OASB Report on IPO Activity and Small Public Companies

The SEC Office of the Advocate for Small Business Capital Formation has released its Annual Report for Fiscal Year 2024, shedding light on the current state of initial public offerings (IPOs) and the challenges faced by small...more

SEC Announces $3.8 Million in Penalties in Continued Enforcement Sweep of Late Beneficial Ownership and Insider Transaction...

Following its previously announced enforcement sweep in September 2023, the Securities and Exchange Commission (SEC) announced on September 25, 2024, that it had settled charges against 23 entities and individuals for failing...more

Biotech Public Markets Finally Thawing(?): Two Massachusetts Biotechs file S-1s

In an encouraging sign that the equity capital markets may be improving for biotechnology companies, Bicara Therapeutics Inc. and Zenas Biopharma, Inc. filed S-1 registration statements yesterday, signaling their intention to...more

SEC Adopts Final Rules Regarding Climate-Related Disclosures

On March 6, 2024, the Securities and Exchange Commission (SEC) adopted, by a 3-2 vote, final rules regarding the enhancement and standardization of climate-related disclosures... The final rules are the culmination of...more

Fifth Circuit Vacates SEC Buyback Disclosure Rule

On December 19, 2023, the Fifth Circuit Court of Appeals vacated the SEC’s share repurchase disclosure rule, which required issuers to: (i) report daily aggregate share repurchase data on a quarterly basis, (ii) indicate if...more

SEC Adopts Final Amendments to Schedule 13D and 13G Requirements

On October 10, 2023, the SEC adopted final amendments to Regulation 13D-G and Regulation S-T to modernize the beneficial ownership reporting regime under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934, as...more

SEC Publishes New Rule 10b5-1 C&DIs

On August 25, 2023, the SEC issued new compliance and disclosure interpretations (C&DIs) related to (i) the December 2022 Rule 10b5-1 amendments and (ii) the related issuer disclosure requirements. The full text of the Rule...more

The Cannabis Rescheduling Recommendation: What it Means and What’s Next

In light of the August 30, 2023 historic recommendation from the U.S. Department of Health and Human Services (HHS) to reschedule cannabis to Schedule III, a multidisciplinary group of attorneys from Foley Hoag’s nationwide...more

SVB Closure: Public Company Disclosure Considerations

Since Friday, March 10, 2023, more than 300 public companies have filed current reports on Form 8-K regarding the closure of Silicon Valley Bank ("SVB"). Company disclosure in these 8-Ks falls essentially into four...more

SEC Amends Rule 10b5-1

In August 2000, the Securities and Exchange Commission (“SEC”) adopted Rule 10b5-1 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), which, among other things, established an affirmative defense to a...more

REMINDER: 2022 Nasdaq Board Diversity Disclosure and D&O Questionnaires

As issuers prepare for the end of the 2021 calendar year and the beginning of the 2022 proxy season, many will soon begin circulating director and officer questionnaires. Nasdaq-listed issuers should consider including new...more

2020: The Year of the SPAC

2020 has been a banner year for IPOs by special purpose acquisition companies, or SPACs. Over 100 SPAC IPOs have closed so far in 2020, with aggregate gross proceeds of approximately $42.1 billion and an average IPO size of...more

SEC Provides Additional COVID-19 Relief

On March 26, 2020, the SEC announced that it is providing additional temporary relief to market participants in light of the COVID-19 pandemic. The relief covers (i) parties needing to file a Form ID to gain access to the...more

SEC Provides COVID-19 Relief for Public Companies

Following the SEC’s announcement on March 4, 2020 that it was providing conditional relief to public companies affected by COVID-19 for their filing obligations under the federal securities laws, many companies have availed...more

SEC Amends “Accelerated Filer” and “Large Accelerated Filer” Definitions

On March 12, 2020, the SEC announced that it has adopted amendments to the “accelerated filer” and “large accelerated filer” definitions to “more appropriately tailor the types of issuers that are included in the definitions,...more

SEC Proposes Amendments to Offering Exemptions

On March 4, 2020, the SEC proposed amendments to existing exemptions from the registration requirements under the Securities Act of 1933 to simplify, harmonize, and improve the existing regulatory framework and to promote...more

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