The SEC recently published the updated version of its EDGAR Filer Manual that includes updates related to filing Forms 144 electronically on EDGAR, as required by the SEC’s final rules adopted back in June. This means the clock on the 6-month transition period from paper to electronic filings of Forms 144 is ticking—all Forms 144
The SEC (Finally) Adopts Pay-for-Performance Rules: 5 Things to Know
Twelve years in the making, the SEC adopted pay-for-performance (P4P) disclosure rules last week in the form of new Item 402(v) of Regulation S-K. Here’s the 234-page adopting release. And here’s the press release and fact sheet.
In 2010, as part of the Dodd-Frank Act, the SEC was directed to adopt pay-for-performance rules.
SEC Finally Mandates E-Filings for Forms 144 and Glossy Annual Reports
Given how old that the SEC’s Edgar now is, it’s always surprising to realize that the SEC still allows some forms to be filed on paper. But those days will soon be behind us as the SEC recently amended its rules to require electronic filing of additional forms, including:
- Forms 144 – Effective six months
Don’t Forget to Review the Graphics in Your Proxy
As lawyers reviewing disclosure documents, it’s easy to gloss over the graphics when conducting a compliance review. But that would be a mistake. Those graphics are as important as any textual disclosure.
Let me give you an example. Quite a few companies include non-GAAP financial measures in proxy disclosure outside of the CD&A discussion of