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Proxy Statements Securities and Exchange Commission (SEC) Policies and Procedures

Keating Muething & Klekamp PLL

Securities Snapshot: 4th Quarter 2024 - 2025 Reporting Season – Key Considerations

As we bid farewell to 2024, we welcome not only another year but also several new disclosure requirements. In this Snapshot, we summarize several developments and best practices for public companies to consider as the 2024...more

Goodwin

When Perquisites Stop Being Fun And Create Serious Liability Risks To An Issuer

Goodwin on

Last week, the U.S. Securities and Exchange Commission (“SEC”) brought enforcement actions against a company and its former CEO for failure to adequately disclose certain compensation and related party transactions. The move...more

Troutman Pepper Locke

New Scrutiny for Hedging Policies

Troutman Pepper Locke on

New SEC disclosure rules regarding hedging are now in effect. As a technical matter, these rules do not require a publicly traded company to implement a hedging policy. They merely require a company to disclose information...more

White & Case LLP

Shareholder Proposals – How the SEC’s Recently Announced New Policy May Impact the Rule 14a-8 No-Action Process

White & Case LLP on

On September 6, 2019, the staff (the “Staff”) of the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) announced1  two significant changes to the Rule 14a-8 no-action process...more

A&O Shearman

Hot Topics: Dodd-Frank Act Hedging Policy Disclosures Begin

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Although final rules were published in December of 2018, July 1st marked the date that issuers (other than smaller reporting companies and emerging growth companies) must begin complying with the Dodd-Frank Act’s hedging...more

Robins Kaplan LLP

ESG Investor Walden Scores Win on CorVel Shareholder Proposal Re LGBTQ Rights

Robins Kaplan LLP on

On June 5, 2019, the Securities and Exchange Commission (SEC) declined to issue a no-action letter to CorVel Corporation with respect to CorVel’s intention to exclude from its proxy materials a shareholder proposal regarding...more

White and Williams LLP

SEC Adopts New Hedging Disclosure Rules

White and Williams LLP on

On December 18, 2018, the Securities and Exchange Commission (SEC) announced that it had approved and adopted final rules requiring public companies to disclose, in proxy or information statements for election of directors,...more

Harris Beach Murtha PLLC

New SEC Rules Will Require Disclosure of Hedging Policies

The Securities and Exchange Commission (SEC) has adopted new rules that will require public companies to disclose their hedging practices and policies for employees, officers and directors in proxy and information statements...more

Bracewell LLP

SEC Adopts Final Rules for Disclosure of Hedging Policies

Bracewell LLP on

The Securities and Exchange Commission recently approved final rules to require disclosure of hedging practices, implementing a Dodd-Frank Act mandate. New Item 407(i) of Regulation S-K requires a company to describe in its...more

Fenwick & West LLP

SEC Adopts New Hedging Disclosure Requirement

Fenwick & West LLP on

In an effort to provide greater transparency to stockholders regarding employee and director incentives, the U.S. Securities and Exchange Commission (SEC) has adopted a final rule implementing a provision of the Dodd-Frank...more

Fenwick & West LLP

SEC Imposes $1.75 Million Penalty Against Issuer for Using Wrong Standard for Disclosing Executive Perquisites

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The U.S. Securities and Exchange Commission announced on July 2, 2018, that The Dow Chemical Company had agreed to a cease and desist order and to pay a $1.75 million penalty for failing to disclose certain expenses as...more

Bass, Berry & Sims PLC

Recent SEC Enforcement Action Reminds Companies that Perquisite Disclosure Does Not Hinge on Business Purpose

Bass, Berry & Sims PLC on

On July 2, the SEC announced that The Dow Chemical Company agreed to settle charges related to the company’s inadequate perquisites disclosure in SEC filings by paying a civil penalty in the amount of $1.75 million, hiring an...more

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