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Misleading Statements Disclosure Requirements

Fox Rothschild LLP

FTC: Be Precise and Accurate With Your Advertising or Beware

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The Federal Trade Commission is taking a hard look at marketing and advertising statements, making sure they are precise and accurate. Here are some key takeaways from recent enforcements:...more

Kelley Drye & Warren LLP

NAD Decision Addresses Review Claims

Yesterday, we posted about a decision in which P&G challenged claims that Rascals made about the absorption capabilities of its diapers. Rascals also advertised: ​“210,000+ 5-star reviews of Rascals Products.” P&G thought...more

Kilpatrick

Are Your Ads Sending the Wrong Message? Lessons from Total Wireless

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The National Advertising Division (“NAD”) recently took Total Wireless, a prepaid brand under Verizon, to task for a TV commercial that blurred the lines between two separate offers, leaving consumers potentially confused....more

Carlton Fields

SEC Commissioners on the Hunt for Materiality: Disagree on Cybersecurity Enforcement Actions

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On October 22, 2024, Republican SEC Commissioners Hester Peirce and Mark Uyeda issued a joint dissent sharply criticizing charges brought against four companies for allegedly making materially misleading disclosures regarding...more

Davis Wright Tremaine LLP

Stay ADvised: 2025, Issue 3

FTC's Final Junk Fees Rule Narrowed in Scope - On December 17, 2024, the Federal Trade Commission (FTC) released its final Rule on Unfair or Deceptive Fees, commonly known as the "Junk Fees Rule." This final rule has a...more

Kohrman Jackson & Krantz LLP

Three Legal Mistakes Influencers Make and How to Avoid Them

In the rapidly evolving world of social media marketing, content creators are an invaluable asset for brands seeking to reach a larger audience. Influencers effectively assist brands in showcasing brand values, gaining...more

Alston & Bird

Sustainability Spotlight - Q3 2024

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Welcome to the latest edition of the Sustainability Spotlight, your place to keep up with all the ESG action – federal and state enforcement, shareholder proposals and litigation, and state attorney general actions. This...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for November 2024

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Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, SEC Chair Gary Gensler announced his imminent departure in January 2025...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update October – November 2024

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The following summarizes recent legal developments of note affecting the mutual fund/investment management industry. On October 21, 2024, the SEC Division of Examinations (“EXAMS”) published its annual Examination Priorities...more

Husch Blackwell LLP

Looking Ahead to the 10-K and Proxy Season: New Requirements and Considerations for the 2025 Reporting Season

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As we approach 2025, we want to remind registrants about several new rules that will impact disclosure for the 2024 Form 10-K and 2025 proxy season, note the 2025 deadlines for filings with the Securities and Exchange...more

Pillsbury Winthrop Shaw Pittman LLP

Disclosure of Non-GAAP Financial Measures: Recent SEC Comments and Enforcement Actions

The U.S. Securities and Exchange Commission (SEC) continues to scrutinize adjustments to, and presentation of, non-GAAP financial measures. Recent SEC enforcement actions for allegedly improper and misleading use of...more

Foley & Lardner LLP

Louisiana Based Franchisor and Its Employees Cannot Avoid Personal Jurisdiction in Washington State

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Washington-state based franchisees Greg and Gabriela Skistimas brought suit against Hotworx Franchising LLC in the U.S. District Court for the Western District of Washington alleging misleading and unfair practices related to...more

Walkers

Listing Act – Part 2: Market Abuse Changes

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EU Listing Act package simplifies listing requirements and post-listing obligations. Targeted amendments to MAR remove disproportionate complexity but preserve investor protection....more

Royer Cooper Cohen Braunfeld LLC

The Pitfalls of “Green Washing”

In a significant development for the investment management industry, a large adviser agreed to pay a hefty $17.5 million civil penalty to settle charges with the SEC over misleading statements about its Environmental, Social,...more

Latham & Watkins LLP

Recent Developments for Directors - November 2024

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SEC Penalizes Director for Misleading D&O Questionnaire Response - The SEC recently brought an enforcement action against a director for causing violations of the proxy rules by failing to disclose a close personal...more

Seward & Kissel LLP

Financial Services Firm Affiliates Settle Five SEC Enforcement Actions for Allegedly Misleading Customers and Failing to Act in...

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Broker Dealers; Compliance Officers; Boards of Directors - Quick Take: The SEC recently settled five separate enforcement proceedings...more

Jones Day

United States Supreme Court to Hear Two Securities Cases This Term

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The Supreme Court is set to hear arguments in two cases concerning the pleading standard in securities fraud class actions....more

BCLP

U.S. Supreme Court to Hear Consequential Case Concerning Public Companies’ Risk-factor Disclosures

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The U.S. Supreme Court has scheduled argument for November 6, 2024 in an important case involving risk-factor disclosures of public companies. At issue is whether a company’s risk disclosures can be treated as false or...more

Wiley Rein LLP

Dissenting Commissioners Criticize SEC’s Latest Cybersecurity Disclosure Cases

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Continuing its controversial and aggressive approaches to cybersecurity, the U.S. Securities and Exchange Commission (SEC) recently charged four current and former public companies for purportedly “materially misleading...more

Baker Botts L.L.P.

Director Independence: Beware of Who Your Friends Are

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The Securities and Exchange Commission (the “SEC”) recently settled charges against James R. Craigie, a former CEO, Chairman and board member of Church & Dwight Co. Inc. (the “Company”), for violating proxy disclosure rules...more

Mintz - Energy & Sustainability Viewpoints

Energy & Sustainability Litigation Updates — November 2024

Despite the recent disbandment of the SEC’s Climate & ESG Task Force, the SEC is continuing to pursue enforcement actions concerning environmental issues, including greenwashing. Notably, over the past several weeks, the SEC...more

Holland & Knight LLP

Undeterred by the SolarWinds Storm: SEC Charges Victims of Compromised Software

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The SEC on Oct. 22, 2024, announced charges against four companies for allegedly making materially misleading disclosures concerning the impact of cybersecurity incidents associated with the compromised SolarWinds' Orion...more

Fenwick & West LLP

The SEC is Cracking Down on Misleading Cybersecurity Disclosure

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On October 22, 2024, the SEC charged two current reporting companies, Unisys Corp. and Check Point Software Technologies, and two former public companies, Mimecast Limited and Avaya Holdings Corp., with making materially...more

Kohrman Jackson & Krantz LLP

The FTC’s New "Click-to-Cancel" Rule: Simplifying Subscription Cancellations for Consumers

On October 16, 2024, The Federal Trade Commission (FTC) announced a significant update to its regulations governing negative option programs. This new “click to cancel” rule aims to make it easier for consumers to cancel a...more

Hinch Newman LLP

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

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On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

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