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SEC Issues Exemptive Order for Section 16 Reports by Directors and Officers of Certain FPIs; Staff Issues New Guidance

On March 5, 2026, the U.S. Securities and Exchange Commission (SEC or Commission) issued an exemptive order relieving directors and officers of certain foreign private issuers (FPIs) from the Section 16(a) reporting...more

Reporting Season Alert: Five Key Considerations for Proxy Season

With the 2026 proxy season upon us, companies are finalizing annual meeting materials against a backdrop of shifting investor priorities, evolving engagement dynamics, and regulatory uncertainty. This alert highlights...more

SEC Adopts Final Rules Under the Holding Foreign Insiders Accountable Act

On February 27, 2026, the U.S. Securities and Exchange Commission (SEC or Commission) announced that it adopted final rule and form amendments implementing the Holding Foreign Insiders Accountable Act (the HFIA Act). The HFIA...more

Foreign Private Issuer Insiders to Be Subject to Section 16(a) Reporting

On December 18, 2025, President Donald J. Trump signed the Fiscal Year 2026 National Defense Authorization Act (NDAA), which includes Section 8103, known as the “Holding Foreign Insiders Accountable Act.” The legislation...more

Reporting Season Alert: Five Key Reminders for Form 10-K Filings

As the year-end reporting season approaches, many public companies are starting preparations for their annual reports on Form 10-K to be filed in early 2026. Below are five key reminders as preparations begin....more

ISS Releases 2026 Benchmark Policy Updates

On November 25, 2025, ISS Governance announced the release of its 2026 Benchmark Policy Updates, which will apply to shareholder meetings on or after February 1, 2026. Set forth below are key changes for U.S. companies. The...more

Rule 10b5-1 Trading Plan Guidelines: A Survey of the SV150

Wilson Sonsini's Rule 10b5-1 Trading Plan Guidelines: A Survey of the SV150 provides an in-depth analysis of the Rule 10b5-1 trading plan guidelines of 75 companies in the Lonergan SV150. The report examines several key...more

Division of Corporation Finance Scales Back No-Action Responses Under Rule 14a-8 for 2025-2026 Proxy Season

On November 17, 2025, the Division of Corporation Finance (the Division) of the Securities and Exchange Commission (the SEC) announced a significant shift in its approach to no-action requests for the current proxy season....more

Insider Trading Policies: A Survey of the SV150

Wilson Sonsini is pleased to present Insider Trading Policies: A Survey of the SV150, which analyzes the insider trading policies of Silicon Valley’s largest public companies....more

SEC Chairman Addresses Potential Reforms Relating to Shareholder Proposals and Shareholder Litigation

On October 9, 2025, Chairman Paul S. Atkins of the U.S. Securities and Exchange Commission (SEC) gave a much-publicized keynote address at the University of Delaware’s John L. Weinberg Center for Corporate Governance. In the...more

Navigating Shareholder Engagement and Shareholder Activism: Essentials and Best Practices

Engaging with shareholders and responding to shareholder activism continue to be top-of-mind for public companies. These situations present opportunities for management teams and boards of directors to work together to...more

SEC Issues Policy Statement Clarifying View on Mandatory Arbitration Provisions

On September 17, 2025, the U.S. Securities and Exchange Commission (SEC or Commission) approved a Policy Statement clarifying the SEC’s position on accelerating the effective date of registration statements for the offer and...more

SEC’s Division of Corporation Finance Issues Views on Disclosure for Securities in Crypto Asset Markets

On April 10, 2025, the SEC’s Division of Corporation Finance (Corp Fin) issued a statement expressing its views about the application of certain disclosure requirements under the federal securities laws to offerings and...more

Corporation Finance Issues Two Unusual Statements Regarding Regulation of Digital Assets

The Division of Corporation Finance (Division) of the Securities and Exchange Commission (SEC) recently issued two statements regarding whether certain tokens, or arrangements involving tokens, constitute “investment...more

SEC Staff Expands Accommodations for Nonpublic Review of Draft Registration Statements

On March 3, 2025, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (Division) announced an expansion of the nonpublic review process for draft registration statements. This expansion aims to...more

2025 Environmental and Social Developments

2025 is off to a fast start with several changes in the legal landscape of the environmental and social (E&S) categories of ESG (Environmental, Social, and Governance). This alert highlights key E&S developments thus far in...more

Preparing for the 2025 Reporting Season: Proxy Season Reminders

With the 2025 proxy season upon us, this Alert highlights governance, disclosure, and engagement considerations for companies preparing for their 2025 annual meetings. Many of the governance and disclosure matters discussed...more

Everything Old Is New Again for Shareholder Proposals: SEC Division of Corporation Finance Issues Staff Legal Bulletin No. 14M

On February 12, 2025, the U.S. Securities and Exchange Commission (the Commission) Division of Corporation Finance staff (the staff) issued Staff Legal Bulletin No. 14M (SLB 14M) to provide informal guidance on shareholder...more

Potential Ramifications of a Government Shutdown for the SEC

If U.S. congressional leaders are unable to pass legislation for continued government funding, it is expected that much of the federal government, including the U.S. Securities and Exchange Commission (SEC), would shut down...more

Nasdaq Board Diversity Rules Struck Down

On December 11, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the U.S. Securities and Exchange Commission’s (SEC’s) order approving The Nasdaq Stock Market LLC’s (Nasdaq’s) board diversity listing standards....more

Preparing for the 2025 Reporting Season: Form 10-K Reminders

With the year-end reporting season on the horizon, this Alert highlights new disclosures and other considerations for annual reports on Form 10-K to be filed in 2025. It also discusses potential updates to D&O questionnaires...more

"Chevron is overruled": How Loper Bright Will Change the Regulatory Law Landscape

In a decision with far-ranging implications for federal administrative law, the United States Supreme Court issued its long-awaited ruling in Loper Bright Enterprises v. Raimondo (Loper Bright).1 The Supreme Court’s...more

SEC, California, and CSRD Climate Disclosure Requirements Comparison Tool

Following an order by the U.S. Securities and Exchange Commission (SEC) implementing a stay of its final climate disclosure rules pending review of legal challenges to such rules in the U.S. Court of Appeals for the Eighth...more

SEC Pauses Climate Disclosure Rules Amid Legal Challenges

On April 4, 2024, the U.S. Securities and Exchange Commission (SEC) issued an order (the Order) implementing a stay of its final climate-related disclosure rules1 adopted on March 6, 2024 (the Final Rules)....more

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