Recently, Corp Fin posted this sample comment letter on XBRL disclosures in an effort to make companies more aware of a focus on improving the quality of XBRL data. As a preface to the sample comment letter, Corp Fin notes there is evidence that investors are using XBRL and Inline XBRL – and that the…

Here is a Client Update from data security lawyers Andrew Pak and Rebecca Engrav that might help you when it comes to assessing the “materiality” of a cybersecurity incident under the SEC’s new Item 1.05 of Form 8-K. The Client Update analyzes some real-world incidents that should help guide how you might update your disclosure controls…

Last week, a Nasdaq rule change went effective immediately that now permits board committees to approve waivers of the code of conduct for directors or executive officers. This changes the rule that required full board approval for these types of waivers. Companies that want to take advantage of this rule change may need to update…

As it does every time around this year, ISS announced that it has released its Annual Global Benchmark Policy Survey. The survey closes on September 21^st. ISS does take the survey seriously, so please do comment if you care about any of the topics.

Globally and in the US, the main focus…

Alas, even the SEC’s registration filing fees aren’t immune to inflation.  Recently, the SEC announced a nearly 34% increase to its registration fees.  Beginning October 1, 2023 – which is the start of the SEC’s fiscal year – the registration fee rate will increase from $110.20 per million dollars to $147.60 per million dollars. 

Securities…

Here’s our latest edition of our monthly feature – a quick snapshot of recent developments:

1. Join us on Thursday, September 28th (from 2:00-3:00 pm eastern) for a webcast – “The SEC’s New Cyber Disclosure Rules – What To Do Now” – to gear up for the new SEC rules regarding cyber disclosure by

Last Friday, Corp Fin issued five new 10b5-1 plan CDIs – three under the Exchange Act Rules and two under Regulation S-K – to provide welcome clarifications for a variety of situations, ranging from the new Form 4 checkbox, cooling-off period calculations, overlapping plans that deal with 401(k) plans, and what to disclose about trading…

This new Client Update deals with the SEC’s concerns over the use of AI in the broker-dealer and investment advisor conflicts context, something that is not within the scope of practice for many of us. But it’s a topic that bears watching as the importance of AI in everything we do grows. Here’s the intro…