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Securities and Exchange Commission (SEC) Publicly-Traded Companies Accelerated Filers

Cooley LLP

What are the latest trends in SOX 404 reporting?

Cooley LLP on

As you probably recall, SOX 404 requires public reporting companies to disclose the effectiveness of their internal control over financial reporting. SOX 404(a) public companies to provide an assessment of ICFR by management;...more

White & Case LLP

Key Considerations for the 2021 Annual Reporting and Proxy Season Part I: Form 10-K Considerations

White & Case LLP on

This is Part I of a two-part memorandum series outlining key considerations from White & Case’s Public Company Advisory Group for US public companies during the 2021 annual reporting and proxy season. Part I of this memo...more

BCLP

Key Takeaways and Reminders for 2021 Form 10-K and Proxy Season

BCLP on

The new year is well underway, and calendar year filers are knee deep in Form 10-K and proxy planning and drafting. Highlighted below are some of the key issues and changes that companies should consider as they continue work...more

Nelson Mullins Riley & Scarborough LLP

July 2020 Task List for Accelerated Filers

Companies that are accelerated filers have a number of things to consider this month. In-line XBRL Is Now Required - First — don’t forget that the in-line XBRL tagging requirements (including for cover pages) have now...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Adopts Amendments to the “Accelerated Filer” and “Large Accelerated Filer” Definitions

Changes are intended to address unintended consequences of 2018 SEC ruling. The amendments to the definitions of “accelerated filer” and “large accelerated filer” pursuant to Rule 12b-2 under the Securities Exchange Act of...more

Mayer Brown Free Writings + Perspectives

Public Float Test Date for Determining Large Accelerated, Accelerated and Small Reporting Company Filer Status

A number of public companies have experienced dramatic fluctuations in their stock price, trading volume and market capitalization as a result of the recent market downturn triggered by the COVID-19 pandemic....more

Mayer Brown Free Writings + Perspectives

SEC Adopts Amendments to Accelerated and Large Accelerated Filer Definitions

On March 12, 2020, the US Securities and Exchange Commission (SEC) adopted amendments to the accelerated filer and large accelerated filer definitions in Rule 12b-2 under the Securities Exchange Act of 1934 (Rule 12b-2). The...more

Goodwin

SEC Amendments Exempt More Smaller Reporting Companies from SOX 404(b) and Accelerated Filing Deadlines

Goodwin on

The Securities and Exchange Commission (SEC) has adopted amendments to the definitions of accelerated filer and large accelerated filer to exclude companies that had annual revenues of less than $100 million in their most...more

Sullivan & Worcester

SEC Adds Revenue Test for Public Companies to be Considered an “Accelerated Filer”

Sullivan & Worcester on

The Securities and Exchange Commission recently adopted amendments to the definitions of “accelerated filer” and “large accelerated filer” that will allow more public companies to qualify as non-accelerated filers, providing...more

Stinson LLP

SEC Amends Filer Definitions; Provides SOX 404(b) Relief for Certain SRCs

Stinson LLP on

The SEC has adopted amendments to the accelerated and large accelerated filer definitions to exclude smaller reporting companies with annual revenues of less than $100 million. As a result of the amendments, these smaller...more

Orrick, Herrington & Sutcliffe LLP

SEC Expands Smaller Reporting Company Relief

Internal Control Over Financial Reporting and Filing Deadlines - On March 12, 2020, the Securities and Exchange Commission adopted amendments to the definitions of “accelerated filer” and “large accelerated filer.”...more

WilmerHale

SEC Reduces ICFR Burdens for Smaller Companies

WilmerHale on

Last week, amidst the focus on the coronavirus, the Securities and Exchange Commission made progress on its short-term rulemaking agenda by amending the definitions of “accelerated filer” and “large accelerated filer.” The...more

Dorsey & Whitney LLP

20-F and 40-F Filers Don’t Get Many of the Benefits of the Amended Accelerated Filer Definition

Dorsey & Whitney LLP on

For Form 10-K filers, the March 12th amendments to the “accelerated filer” definition made sense and helped better coordinate the “smaller reporting company” definition with the “accelerated filer” definition. The amendments...more

Dorsey & Whitney LLP

SEC Amends Definition of Accelerated and Large Accelerated Filer

Dorsey & Whitney LLP on

On March 12, 2020, the Securities and Exchange Commission (the “Commission”) adopted amendments to the “accelerated filer” and “large accelerated filer” definitions in the Rule 12b-2 under the Securities Exchange Act of 1934,...more

Proskauer Rose LLP

SEC Excludes Certain BDCs from Accelerated Filer and Large Accelerated Filer Status

Proskauer Rose LLP on

On March 12, 2020, the Securities and Exchange Commission (the "SEC") adopted amendments to the definitions of accelerated filer and large accelerated filer in Rule 12b-2 under the Securities Exchange Act of 1934, as amended....more

Stinson - Corporate & Securities Law Blog

Expanded Analysis: SEC Amends Accelerated Filer and Large Accelerated Filer Definitions, Provides SOX 404(b) Relief

On March 12, 2020, the Securities and Exchange Commission adopted long-awaited amendments to the accelerated filer and large accelerated filer definitions with the stated goal of “reduc[ing] unnecessary burdens for certain...more

Morgan Lewis

SEC Amends Definitions of Accelerated and Large Accelerated Filers

Morgan Lewis on

The US Securities and Exchange Commission announced that it voted on March 12 to adopt amendments to the definitions of “accelerated filer” and “large accelerated filer” in Rule 12b-2 of the Securities Exchange Act of 1934,...more

Mayer Brown Free Writings + Perspectives

New Definitions of Accelerated and Large Accelerated Filer

The Securities and Exchange Commission adopted amendments to the accelerated filer and large accelerated filer definitions, which impact the Sarbanes-Oxley Act of 2002....more

Stinson - Corporate & Securities Law Blog

SEC Amends Accelerated Filer and Large Accelerated Filer Definitions

The SEC has adopted amendments to the accelerated filer and large accelerated filer definitions. The amendments exclude from the accelerated and large accelerated filer definitions an issuer that is eligible to be a smaller...more

Snell & Wilmer

The SEC Publishes Interpretative Guidance Following Initial Transition to Inline XBRL

Snell & Wilmer on

As a reminder, in June 2018 the SEC adopted new rules relating to its eXtensible Business Reporting Language (“XBRL”) requirements. The new rules require companies to file interactive data in a new format named Inline XBRL....more

Stinson - Corporate & Securities Law Blog

Preliminary Planning for the 2020 Proxy Season

Our preliminary list of important planning considerations for the 2020 proxy season is set forth below. Directors’ and Officers’ Questionnaires; Committee Charters - We have identified only a few possible changes to...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposal Would Relax ICFR Auditor Attestation Requirement for Certain Smaller Reporting Companies

In an effort to reduce compliance costs for public companies, the Securities and Exchange Commission (SEC) proposed amendments on May 9, 2019, that, in part, relax the requirement for certain “smaller reporting companies”...more

McDermott Will & Emery

Capital Markets & Public Companies Quarterly: SEC Proposes Amendments to Accelerated and Large Accelerated Filer Definitions,...

McDermott Will & Emery on

During the previous quarter, the SEC proposed new rulemaking to reduce the number of smaller companies that become subject to enhanced reporting requirements through “accelerated filer” and “large accelerated filer” status....more

Jones Day

SEC Proposes Amendments to "Accelerated Filer" and "Large Accelerated Filer" Definitions

Jones Day on

The Situation: The U.S. Securities and Exchange Commission ("SEC") proposed amendments to the definitions of "accelerated filer" and "large accelerated filer" under the Securities Exchange Act of 1934. The Result: The...more

White & Case LLP

SEC Continues on the Path of Simplifying Public Company Requirements

White & Case LLP on

New Proposed Rules Aim to Eliminate Auditor's Attestation Requirement on Internal Controls under SOX 404(b) for Smaller Reporting Companies with less than $100 million in Revenues - On May 9, 2019, the SEC proposed...more

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