The SEC Division of Corporation Finance has updated its October 1, 2025 guidance regarding actions in advance of a potential government shutdown, with the revised version dated October 9, 2025. The most significant substantive change relates to update guidance in response to the question of whether registrants can file an…
Absent action by Congress, a lapse in appropriation will occur following the end of the federal government’s fiscal year on September 30. In the event of a lapse in appropriations, it is expected that the SEC’s normal operations will be curtailed, as has been the case in prior government shutdown…
On September 10, 2025, the SEC announced that an open meeting will be held on September 17, 2025 and the agenda items include: Whether to issue a policy statement addressing the presence of a provision requiring arbitration of investor claims arising under the federal securities laws and its impact on…
On September 10, 2025, the SEC announced that James J. Moloney, a partner at Gibson Dunn, has been named Director of the agency’s Division of Corporation Finance, effective in October. He previously served on the SEC Staff in the Division of Corporation Finance from 1994 to 2000. The announcement notes…
On July 24, 2025, Institutional Shareholder Services (ISS) announced the launch of its Annual Global Benchmark Policy Survey. In its announcement, ISS notes: This year’s survey begins with core governance topics, including shareholder rights in relation to multi-class capital structures, considerations with regard to shareholder proposals, and board governance, with…
On July 21, 2025, the SEC announced that it has designated George R. Botic to serve as Acting Chair of the Public Company Accounting Oversight Board, effective July 23, 2025. The PCAOB announced last week that Chair Erica Williams will depart the Board on July 22. The SEC’s announcement notes…
On July 16, 2025, the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) announced the withdrawal of its draft Corporate Governance Framework (“CGF”). The announcement notes that “[t]he draft CGF has been withdrawn from public comment as COSO takes time to evaluate the extensive feedback received to date and…
Today, the SEC issued a concept release to solicit public comment on the definition of foreign private issuer (“FPI”). It has been many years since the SEC last considered what it means to qualify as a FPI. While it is too early to predict how the SEC might ultimately revise…
On May 16, 2025, the SEC announced that it will hold a roundtable on June 26, 2025 to discuss the SEC’s executive compensation disclosure requirements. The roundtable will be open to the public at the SEC’s headquarters and through a live stream available on www.sec.gov. The SEC encourages members of…
As the Trump Administration approaches 100 days in office, we explore the key policy shifts and regulatory changes affecting business and markets across industries in our New Directions Audio Series. For public companies and companies seeking to raise capital, we discuss the SEC’s latest initiatives on capital raising, and we also…