News & Analysis as of

Public Comment Disclosure Requirements Proposed Rules

Sheppard Mullin Richter & Hampton LLP

Commercial Division Moves Towards Adopting Additional Initial Disclosure Requirements

While the Commercial Division Rules are closer to the Federal Rules of Civil Procedure than any other set of court rules in New York (including the base requirements of the CPLR), they are far from identical. One area where...more

Goodwin

SEC Outlook: Potential Updates Under Nominated Chairman Atkins

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The SEC currently has several notable rule proposals that have received public comment but have not yet been finalized. The potential direction of these proposals is likely to be influenced by the leadership of the new SEC...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Venable LLP

FTC Releases Proposed Rule Targeting “Junk” Fees

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This week, the Federal Trade Commission (FTC) released a Proposed Rule, “Rule on Unfair or Deceptive Fees.” The Proposed Rule comes after the FTC solicited comments through its Advance Notice of Proposed Rulemaking in...more

Holland & Knight LLP

'Tis the Season … to Reopen Public Comment on SEC's Share Buyback Rule Proposal?

Holland & Knight LLP on

The SEC announced on Dec. 7, 2022, a second reopening of the public comment period for its proposed Share Repurchase Disclosure Modernization rule (Rule), first proposed on Dec. 15, 2021. The initial 45-day comment period was...more

Holland & Knight LLP

SEC Reopening Comment Period on Several Key Proposed Rules After Technical Error

Holland & Knight LLP on

The SEC on Oct. 7, 2022, reopened the comment period for 11 rule making proposals, one request for comment and eight Self-Regulatory Organization (SRO) matters – all due to a technical error. This glitch likely throws a...more

Orrick, Herrington & Sutcliffe LLP

Comment Period Reopened for Climate and Cybersecurity Proposals, Among Others

On Friday, October 7, 2022, the Securities and Exchange Commission (the “SEC”) reopened the public comment periods for eleven rulemaking proposals and one request for comment due to a technical error that prevented the SEC...more

Alston & Bird

SEC Reopening Comments After Technical Issues

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The Securities and Exchange Commission has reopened comments for nearly two dozen proposed rules and other matters. Our Securities Group details the list that includes some controversial rules about cybersecurity, SPACs, and...more

Vinson & Elkins LLP

A Second Chance: The SEC Reopens Comment Periods on Climate, Cyber and Other Rule Proposals in Response to Technical Glitch

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A technological error in the online comment portal on sec.gov has prevented the Securities and Exchange Commission (“SEC”) from receiving comments on twelve rule proposals (the “Affected Proposals”), according to a new SEC...more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Periods for Certain Rulemaking Releases

On October 7, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it will reopen the public comment periods for 11 rulemaking releases and one request for comment due to a technological error that resulted...more

Cooley LLP

The SEC calls “technical glitch”—what happened to your comment letter?

Cooley LLP on

Surprise! The SEC has just reopened a slew of comment periods! Late Friday, the SEC announced that, as a result of a technical error, it had not received a number of electronically submitted comments for at least 11...more

Sheppard Mullin Richter & Hampton LLP

New York Publishes Proposed Rules on Commercial Financing Disclosures

On September 14, the New York Department of Financial Services (NYDFS) published a notice of proposed rules under New York’s Commercial Financing Disclosure Law (CFDL)...more

Eversheds Sutherland (US) LLP

USDA seeks comments on annual updates to list of bioengineered foods

On July 22, 2022, the US Department of Agriculture’s (USDA) Agricultural Marketing Service (AMS) opened up public comment on a proposed rule to make two changes to the List of Bioengineered Foods (the List). The National...more

Zuckerman Spaeder LLP

SEC Extends Comment Period on Proposed Rules Requiring Robust Climate-Related Disclosures

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On May 9, the U.S. Securities and Exchange Commission (“SEC”) announced that it will extend the public comment period on its proposed rules on climate-related disclosures by public companies. The comment period was scheduled...more

Cooley LLP

SEC extends comment period for climate disclosure proposal

Cooley LLP on

Yesterday, the SEC announced that it had extended or reopened the public comment period on three proposals, including the proposed rulemaking to enhance and standardize climate-related disclosures. (See this PubCo post, this...more

Woodruff Sawyer

Governance Disclosure and the SEC’s Proposed Climate Rules

Woodruff Sawyer on

On March 21, 2022, the Securities and Exchange Commission (“SEC”) proposed rule amendments (the “Proposed Rules”) that would require most US public companies and foreign private issuers to include certain climate-related...more

WilmerHale

ESG on Earth Day: Climate Risk is Financial Risk

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Today marks the 52nd Earth Day celebration, initially commenced in 1970 as citizens around the nation, and the world, gathered to demand stronger protection for the environment: cleaner water, air and land. As in 1970, the...more

Seyfarth Shaw LLP

SEC Proposes Mandatory Cybersecurity Disclosures by Public Companies

Seyfarth Shaw LLP on

Introduction - On March 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed mandates for cybersecurity disclosures by public companies. If adopted, these mandates seek to provide investors a deeper look...more

Goodwin

SEC Proposes Rule Amendments Requiring Climate — Related Disclosures

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SEC Proposes Rule Amendments Requiring Climate-Related Disclosures; Southern District of New York Dismisses Securities Fraud Claims Against U.S. Stock Exchanges for Lack of Standing; Southern District of New York Dismisses...more

McGuireWoods LLP

SEC Releases Proposed New Rules on Climate-Related Disclosures

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On March 21, 2022, the U.S. Securities and Exchange Commission (SEC) issued proposed rules to significantly expand and standardize climate-related disclosures in SEC periodic reports and registration statements. According to...more

Goodwin

SEC Proposes New Rules Applicable To SPACs And Certain Reverse Mergers

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On March 30, 2022, the U.S. Securities and Exchange Commission (SEC or Commission) held an open meeting to consider proposed rules and amendments regarding special purpose acquisition companies (SPACs), shell companies, and...more

Kelley Drye & Warren LLP

SEC Proposes New Rules on Cybersecurity Disclosures: Four Things to Know

On March 9, the U.S. Securities and Exchange Commission (SEC) announced proposed amendments to its rules regarding cybersecurity disclosures to satisfy a growing investor need to know more about how registrants are managing...more

Moore & Van Allen PLLC

SEC Announces Proposed Rule for Climate Risk and Greenhouse Gas Disclosures

Moore & Van Allen PLLC on

On March 21, 2022, the U.S. Securities and Exchange Commission (“SEC”) announced a proposed rule (the “Proposed Rule”) that will require registrants to make certain climate disclosures in their registration statements and...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes New Rules for Climate-Related Disclosures

On March 21, 2022, the Securities and Exchange Commission (SEC) voted 3-1 to propose long-anticipated rules mandating climate-related disclosures in companies’ annual reports and registration statements. The proposed rules...more

Cooley LLP

SEC proposes new rules on climate disclosure [UPDATED—PART II—GHG emissions]

Cooley LLP on

[This post is Part II of a revision and update of my earlier post that primarily reflects the contents of the proposing release. Part I (here) covered the background of the proposal and described the SEC’s proposed climate...more

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