This client alert authored by Kathryn Campbell, Gina Buschatzke and Emily Craven covers what some senior SEC Enforcement officials discussed at a recent conference.  The bottom line is that the SEC’s intention is clear – to continue to pursue enforcement actions aggressively.

Last week, a California Superior Court in Los Angeles County delivered this Crest v. Padilla decision that found that the California law requiring that California-headquartered companies have a minimum number of women directors – known as “SB 826” – violates the California Constitution’s Equal Protection Clause. This decision comes on the heels of a lengthy…

Not surprising given how so many companies have been struggling over the past month to keep up with the changes wrought by Russia’s invasion of Ukraine, Corp Fin posted this “sample letter to companies” last week regarding disclosure about the invasion and the related supply chain issues. The Corp Fin Staff has begun…

A few weeks ago, SEC Commissioner Crenshaw delivered a speech on SPACs that’s worth reading. Agree or disagree, it’s an excellent summary of the policy considerations behind the SEC’s recent rule proposal regarding SPAC IPOs – and a helpful reminder of the challenges to keep in mind for those navigating a SPAC transaction. Here’s the…

I’m excited to share our firm memo – “SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance” – authored by Valerie Dahiya and David Aaron. Check it out!

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Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about a board’s oversight of climate-related matters. For some companies, this type of disclosure undoubtedly would impact how much time and resources they devote to climate issues going forward.

The Disclosure Requirements

As noted starting on page 93…

Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about a company’s climate targets and goals – for those companies that have done that sort of thing.

We have blogged before about things to consider when companies publicly announce a climate pledge. Most companies making such pledges…

Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would expand Regulation S-X and create specific requirements for a note to financial statements addressing climate change issues in a number of ways.

This is a big deal. By requiring this type of disclosure in the financial statements, the SEC’s rules…