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SEC Seeks Crypto Specialist

The SEC’s Division of Trading and Markets is seeking a Crypto Specialist to coordinate activities regarding crypto and digital asset securities....more

SEC Chair Discusses Human Capital Disclosure

SEC Chairman Jay Clayton gave his views on appropriate disclosures related to human capital in opening remarks before a meeting of the SEC Investor Advisory Committee....more

SCOTUS Finds Investment Banker Liable for Cutting and Pasting Fraudulent Statement

The U.S. Supreme Court considered the extent of liability under Rule 10b-5 and other rules of the Securities and Exchange Commission and related statutes in Lorenzo v. Securities and Exchange Commission. The facts of the...more

SEC Official Speaks to Sustainability Disclosure

William Hinman, Director, SEC Division of Corporation Finance, recently gave his views on sustainability disclosures by public companies, among other topics....more

SEC Seeks Comment on Application of Custody Rule to Digital Assets

The SEC’s Division of Investment Management is seeking comment on the application of the Custody Rule to digital assets. ...more

SEC Comments on Pay Ratio Disclosures (None)

We have been unable to find extensive SEC comments on last year’s first round of pay ratio disclosures. Searches for comment letter responses referring to for “402(u)” or “pay ratio” do not seem to turn up anything of...more

SEC proposes to Expand Test-the-Waters Communications to all Issuers

The SEC has proposed new rules that would permit all issuers to solicit investor views about potential offerings at an earlier stage in the offering process than is the case today. ...more

SEC Proposes to Expand “Test-the-Waters” Communications to all Issuers

The SEC has proposed new rules that would permit all issuers to solicit investor views about potential offerings to be taken into account at an earlier stage in the process than is the case today....more

Crypto Mom Warns SEC of Over Expansive Definition of Howey in Token Offerings

SEC Commissioner Hester M. Peirce was awarded the nick name “Crypto Mom” by digital asset aficionados in a previous speech encouraging forward thinking by the SEC in the regulation of tokens and initial coin offerings....more

SEC Provides Guidance on Diversity Disclosures

In two new Compliance and Disclosure Interpretations (Questions 116.11 and 133.13), the SEC staff provided guidance on disclosure of self-identified specific diversity characteristics of board members and board nominees. ...more

SEC Wants to Monitor Blockchain

The SEC is conducting market research to determine the availability and technical capability of large and small businesses to provide blockchain data to support the SEC’s efforts to monitor risk, improve compliance, and...more

SEC Says Disclosing Material Internal Control Weaknesses is not a Substitute for Maintaining Internal Controls

The SEC announced settled charges against four public companies for failing to maintain internal control over financial reporting, or ICFR, for seven to 10 consecutive annual reporting periods. ...more

SEC Adopts Rules to Permit Public Companies to Use Regulation A+

As required by the Economic Growth, Regulatory Relied and Consumer Protection Act, the SEC has adopted final rules which will permit public companies to rely on the exemption from registration to offer securities in amounts...more

SEC Initiates Enforcement Action for Failure to Present GAAP with Equal or Greater Prominence

The SEC brought a settled enforcement action against ADT Inc. because it did not afford equal or greater prominence to comparable GAAP financial measures in two of its earnings releases containing non-GAAP financial...more

The First CAM

The critical audit matter communicated here is a matter arising from the current period audit of the financial statements that was communicated or required to be communicated to the audit committee and that: (1) relates to...more

SEC Brings Enforcement Action for Failure to Verify Accredited Investor Status

CoinAlpha Advisors LLC was formed for the purpose of investing in digital assets. From October 2017 through May 2018 CoinAlpha raised approximately $600,000 from 22 investors, residing in at least five U.S. states....more

Court Refuses to Issue Preliminary Injunction to Halt Initial Coin Offering

In SEC v. Blockvest, LLC, the United States District Court for the Southern District of California examined the SEC’s argument for a preliminary injunction halting an initial coin offering, or ICO....more

SEC Tells How to Fix the Faulty Initial Coin Offering

The SEC simultaneously announced a pair of settled enforcement actions related to illegally offered ICOs with extensive remedial provisions to fix the faulty offerings....more

SEC Approves Revised Nasdaq Rule for Shareholder Approval of Private Placements

The SEC has approved an amendment to Nasdaq Rule 5635(d) to modify the circumstances in which shareholder approval is required for issuances of securities in private placement transactions....more

Elon Musk, Twitter and Disclosure Controls and Procedures

In perhaps the fastest moving SEC enforcement action of all time, the SEC charged Elon Musk with securities fraud on September 27, 2018 after settlement agreements reportedly fell apart....more

SEC Staff Provides Relief for Form 10-Qs under Disclosure Simplification Rules

SEC staff recently issued this Compliance and Disclosure Interpretation: Question 105.09 - Question: On August 17, 2018, the SEC adopted amendments to certain disclosure requirements in Securities Act Release No....more

Guide to the Effect of the SEC’s Disclosure Simplifications on SEC Filings

The SEC has adopted amendments to its rules simplify disclosures in filings with the SEC. The amendments eliminate certain...more

SEC Issues C&DIs on Exempt Solicitations

We recently noted a shareholder proponent had been making aggressive use of Notices of Exempt Solicitation on EDGAR. ...more

SEC Staff to Hold Roundtable on the Proxy Process

In 2010, the SEC issued a concept release seeking public comment on whether the U.S. proxy system as a whole operates with the accuracy, reliability, transparency, accountability, and integrity that shareholders and companies...more

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