On December 18, 2025, President Trump signed the National Defense Authorization Act (“NDAA”) into law. Among its many provisions, Section 8103—titled the “Holding Foreign Insiders Accountable Act”—introduces a significant development for foreign private issuers (“FPIs”). Section 8103 amends Section 16(a) of the Securities Exchange Act of 1934 to extend its…
On December 11, 2025, President Trump signed an executive order entitled “Protecting American Investors From Foreign-Owned and Politically-Motivated Proxy Advisors.” Directly referencing Institutional Shareholder Services (ISS) and Glass Lewis, the order is predicated on the premise that “proxy advisors regularly use their substantial power to advance and prioritize radical politically-motivated…
As we previously posted, on November 17, 2025, the SEC’s Division of Corporation Finance announced a significant change in how it will engage with shareholder proposal exclusions. Just two days later, on November 19, 2025, the Staff issued what appears to be the first public response letter under its revised…
In a Friday appearance on Fox Business, SEC Chairman Paul Atkins signaled that the Securities and Exchange Commission is increasingly focused on curbing the influence of proxy advisory firms. His comments follow reports that the Trump Administration is weighing an executive order aimed at limiting the role of firms such…