On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule identifying Buy Now, Pay Later Lenders (BNPL Lenders or Lenders) as “card issuers” or “creditors” for the purposes of Regulation Z,...more
On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more
Late last week, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule that provided much-welcome guidance related to the effect of the new Juneteenth National Independence Day on disclosure waiting...more
The SEC issued documents on January 30, 2020, regarding management discussion and analysis (MD&A) and other disclosures. ...more
In March 2019, final rules amending Regulation S-K and related rules and forms were adopted. Included in these rules were requirements that registrants use Inline XBRL, a machine-readable computer code, to tag certain...more
At an open meeting today, the Securities and Exchange Commission issued guidance to assist investment advisers in fulfilling their proxy voting responsibilities in using the services of a proxy advisory firm, and provided...more
Amid concerns that many investors may not fully understand the risks associated with virtual currencies, or the limits of regulatory oversight, the National Futures Association (NFA) recently issued an interpretive notice...more
The SEC’s recent proposed guidance for investment advisers has implications for private equity sponsors. Perhaps the most important part of the guidance for private equity sponsors is that related to the duty of loyalty...more
On February 21, the Securities and Exchange Commission (SEC) published interpretive guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents....more
Much has been written about the SEC’s interpretive guidance on cybersecurity disclosures, issued in late February, including Commissioner Stein’s statement that it under-delivers for investors, public companies, and the...more
Prompted by concern over the increase in the risks and frequency of data breach incidents and other cyber-attacks affecting public companies, the Securities and Exchange Commission recently published interpretive guidance to...more
It’s been seven years since the U.S. Securities and Exchange Commission (Commission) issued its initial guidance to public companies on cybersecurity disclosure. And last week – in the midst of Form 10-K filing season –...more
The SEC's new guidance on public company cybersecurity disclosures and Chairman Clayton's accompanying statement emphasize the SEC's expectations that public companies: (i) implement comprehensive cybersecurity policies that...more
This week, the U.S. Securities and Exchange Commission (SEC) issued its first formal interpretative release on public company disclosure obligations relating to cybersecurity since the SEC Division of Corporation Finance’s...more
On February 21, 2018, the U.S. Securities and Exchange Commission approved the release of Interpretive Guidance relating to public company disclosures of cybersecurity risks and incidents. ...more
Two pieces of guidance emerged from the SEC on September 21, 2017, with respect to the pay ratio rule. First, the Commission issued interpretive guidance on the rule. Second, the Division of Corporation Finance also issued...more