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Investors Sue to Invalidate Rule 14a-8 Amendments

The Interfaith Center on Corporate Responsibility, James McRitchie and As You Sow have sued the SEC to invalidate the most recent amendments to Rule 14a-8 which permits small shareholders to submit proposals to public...more

SEC Charges Issuer with Cybersecurity Disclosure Controls Failures

The SEC announced a settled enforcement action concerning First American Financial Corporation’s violations of disclosure controls and procedures.  The violations related to disclosures made in connection with a cybersecurity...more

Gensler Hints at Proposed Changes to Rule 10b5-1

In public remarks SEC Gary Gensler hinted at the following changes to Rule 10b5-1: - When insiders or companies adopt 10b5-1 plans, there’s currently no cooling off period required before they make their first trade....more

SEC Charges Eight Companies for Failure to Disclose Complete Information on Form NT

The Securities and Exchange Commission charged eight companies for failing to disclose in SEC Form 12b-25 filings, commonly known as Form NT, that their request for seeking a delayed quarterly or annual reporting filing was...more

House Passes Legislation Addressing 10b5-1 Plans

The House of Representatives has passed the “The Promoting Transparent Standards for Corporate Insiders Act” (H.R. 1528) by a vote of 355-69.  The bill directs the Securities and Exchange Commission to study and report on...more

SEC Risk Alert Notes Deficiencies in ESG Investing Processes

The SEC Division of Examinations has issued a Risk Alert to highlight observations from recent exams of investment advisers, registered investment companies, and private funds offering ESG products and services....more

Corp Fin Director Questions Application of PSLRA to De-SPAC Transactions

John Coates, Acting Director, Division of Corporation Finance, issued a statement questioning the application of the safe harbor for forward looking information in the Private Securities Litigation Reform Act (PSLRA) to a...more

SEC Warns SPAC Targets the Road May be Difficult

The SEC issued two pieces of guidance on special purpose acquisition companies, or SPACs.  One piece, styled as a statement by Paul Munter, Acting Chief Accountant, speaks to financial reporting and auditing considerations of...more

Resolution Introduced to Invalidate Revisions to Shareholder Proposal Rules

In September 2020 the SEC adopted final rules altering the shareholder proposal framework for the first time in 20 years. Following another split-vote of the Commissioners, the SEC approved modifications to the current...more

SEC Adopts Interim Amendments for the Holding Foreign Companies Accountable Act

The SEC has adopted interim final amendments to Form 10-K, Form 20-F, Form 40-F, and Form N-CSR to implement the disclosure and submission requirements of the Holding Foreign Companies Accountable Act, or the HFCA Act....more

Delaware to Consider Public Policy of Assisting Shell Company Mergers

In re Forum Mobile, Inc. considers petitioner Synergy Management Group LLC’s request for the appointment of its President to be custodian of Forum Mobile, Inc. under Section 226(a)(3) of the Delaware General Corporation Law,...more

SEC Brings Charges for Failure to Disclose Perks

The Securities and Exchange Commission announced settled charges against an Oklahoma-based gas exploration and production company, Gulfport Energy Corporation, and its former CEO, Michael G. Moore, for failing to properly...more

SEC Announces Enforcement Task Force Focused on Climate and ESG Issues

The Securities and Exchange Commission announced the creation of a Climate and ESG Task Force in the Division of Enforcement. Consistent with increasing investor focus and reliance on climate and ESG-related disclosure and...more

SEC Charges AT&T and Three Executives with Selectively Providing Information to Wall Street Analysts to Talk Down Estimates

On March 5, 2021, the Securities and Exchange Commission charged AT&T, Inc. with repeatedly violating Regulation FD, and three of its Investor Relations executives with aiding and abetting AT&T’s violations, by selectively...more

Acting SEC Chair Orders Review of Climate Disclosures

In a public statement Acting SEC Chair Allison Herren Lee noted that he had directed the Division of Corporation Finance to enhance its focus on climate-related disclosure in public company filings....more

SEC Adopts Final Rules for the Disclosure of Payments by Resource Extraction Issuers

The SEC adopted final rules that will require resource extraction issuers that are required to file reports under Section 13 or 15(d) of the Securities Exchange Act of 1934 to disclose payments made to the U.S. federal...more

Form for an Officer/Director to Attest to an Electronic Signature on an SEC Filing

The SEC has adopted final rules regarding electronic signatures with respect to Regulation S-T Rule 302. New Rule 302(b)(2) of Regulation S-T provides that, before a signatory initially uses an electronic signature to sign...more

SEC Amends Rules for MD&A and other Financial Disclosures

The SEC adopted amendments intended to modernize, simplify and enhance certain financial disclosure requirements in Regulation S-K, including rules related to MD&A....more

SEC Commissioners Explain Dissent from Enforcement Action Related to 10b5-1 Plan

We previously discussed an SEC enforcement action against Andeavor LLC for controls violations relating to a stock buyback plan it implemented while it was in discussion to be acquired by Marathon Petroleum Corp. in 2018....more

SEC Harmonizes and Improves Exempt Offering Framework

The SEC adopted final rules which the SEC believes harmonizes, simplifies, and improves the complex exempt offering framework....more

SEC Charges Company for Implementing Stock Buyback Plan Before Acquisition Negotiations Resumed

The SEC announced settled charges against Andeavor LLC for controls violations relating to a stock buyback plan it implemented while it was in discussions to be acquired by Marathon Petroleum Corp. in 2018. Andeavor agreed to...more

SEC Proposes Expanded Exemption for “Finders”

At an open meeting of the Securities and Exchange Commission on October 7th, the Commission approved issuance of a proposed conditional exemptive order that would allow “finders” to engage with accredited investors in...more

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