News & Analysis as of

SEC Comment Letter Process Tandy Letter

McDermott Will & Emery

Capital Markets & Public Companies Quarterly: Potential Shift in SEC’s Proxy Access No-Action Policy and Other New Guidance from...

McDermott Will & Emery on

The third quarter of 2016 saw the US Securities and Exchange Commission (SEC) carry forward its momentum from an active second quarter. Recent developments include new SEC Compliance & Disclosure Interpretations (C&DI) and...more

Parker Poe Adams & Bernstein LLP

Tandy Reps are No More

The SEC announced on October 5th that, effective immediately, “Tandy” representations are no longer required in company responses to SEC comment letters. Practically speaking, this requires only a simple template modification...more

Broker-Dealer Compliance + Regulation

Randy “Tandy” Dandy No More

On October 5, 2016, the SEC unceremoniously dropped a long-standing requirement that issuers affirmatively state that they will not raise the SEC review process and acceleration of effectiveness as a defense to legal...more

Skadden, Arps, Slate, Meagher & Flom LLP

'Tandy' Representations No Longer Required in Responses to SEC Staff Comments

The U.S. Securities and Exchange Commission’s Division of Corporation Finance announced that the staff will no longer require companies to provide the so-called “Tandy” representations in response to staff comments on a...more

Allen Matkins

Unilateral Disarmament, The Prisoners’ Dilemma And SEC Staff Comment Letters

Allen Matkins on

In an arms race, each suffers the worst result if it disarms and the other side remains armed. However, if both sides are armed, they are not as well off as when both sides are disarmed. This is, of course, the classic...more

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