News & Analysis as of

Disclosure Requirements Securities and Exchange Commission (SEC) Chief Compliance Officers

Society of Corporate Compliance and Ethics...

[Virtual Event] ESG and Compliance Conference - November 7th, 8:00 am - 5:00 pm CT

Stay on top of ever-evolving ESG requirements and emerging trends - With the SEC’s newly issued rules surrounding ESG disclosures and the continued growth of regulations rolling out in the EU, Canada, Asia and elsewhere...more

Latham & Watkins LLP

Form N-PX “Say on Pay” Disclosure Requirement for 13F Filers Will Become Effective July 1, 2024

Latham & Watkins LLP on

Form 13F filers will need to file their first Form N-PX covering the period of July 1, 2023, to June 30, 2024, by August 31, 2024. Rule 14Ad1 of the Securities Exchange Act of 1934 (Exchange Act), which was adopted by...more

NAVEX

Bringing Together the People, Processes, and Tools for Cyber Risk Management

NAVEX on

Last month I wrote a post for this blog about the Securities and Exchange Commission’s proposals for more disclosure of cybersecurity issues. We reviewed some of the governance disclosures that boards might need to make, as...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for March 2022

As a fitting cap to a busy month, on March 30, the SEC Division of Examinations announced its 2022 Examination Priorities. These priorities are consistent with the recent activities of the SEC more generally, as exemplified...more

A&O Shearman

SEC Proposes New Large Position Reporting Requirements and Prohibitions on Fraud and Manipulation For Security-Based Swaps

A&O Shearman on

On December 15, the Securities and Exchange Commission (SEC) proposed a series of potentially far-reaching changes to the regulation of the security-based swap (SBS) markets. Among other changes, the proposed rules would...more

Eversheds Sutherland (US) LLP

SEC’s focus on compliance: What boards should know

Rule 38a-1 under the Investment Company Act of 1940 (the 1940 Act) requires funds to review their compliance programs, as well of those of their service providers, including their investment advisers (advisers), annually....more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

NAVEX

It's Time To Address Climate Change Risks: Regulations to Come

NAVEX on

Corporations have reached a tipping point on climate change. They understand that requirements are coming for new disclosures about climate change risk, and fighting such regulation is a fruitless effort. So the challenge...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

U.S. Financial Industry Developments - SEC Disapproves the Listing and Trading of Nine Bitcoin Related Exchange Traded Products - On August 22, 2018, the SEC released three Orders, acting through authority delegated to...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Topics on SEC/Corporate, Broker/Dealer, CFTC and UK/EU/Brexit Developments

SEC/CORPORATE - SEC Adopts Amendments To Simplify and Update Certain Disclosure Requirements - On August 17, the Securities and Exchange Commission announced the adoption of proposed rule amendments (Amendments) to...more

Latham & Watkins LLP

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

Latham & Watkins LLP on

Summary of private equity firms’ compliance obligations, discussion of notable developments in 2017, and outlook for 2018. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more

WilmerHale

Dodd-Frank Implementation Update: Key Differences Between the CFTC and SEC Final Business Conduct Standards and Related...

WilmerHale on

The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more

Thomas Fox - Compliance Evangelist

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Dorsey & Whitney LLP

SEC Sanctions Another Entity For Not Following Its Procedures

Dorsey & Whitney LLP on

A continuing focus of SEC enforcement is compliance by entities with their disclosed procedures. The Commission’s latest action in this regard resulted in the payment of $6 million by a Credit Rating Agency that not only...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more

Locke Lord LLP

The Foreign Corrupt Practices Act: At a Glance

Locke Lord LLP on

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

Akin Gump Strauss Hauer & Feld LLP

Executive Compensation Considerations for 2014

Executive compensation is a topic that just won’t go away, particularly with pay disparity and pay for performance regulations still looming. We highlight below some of the matters directors should be considering as they...more

Manatt, Phelps & Phillips, LLP

A Roadmap for Audit Committees in Meeting the Challenges Posed by Enhanced Regulatory Scrutiny Under the Dodd-Frank Act

Audit committees must aid management in navigating an increasingly complex regulatory framework. Two recent developments arising from the passage and implementation of the Dodd-Frank Act have led to further challenges for...more

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