The Securities and Exchange Commission (SEC) recently updated its implementation timeline for new rules under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). One of the rules, disclosure related to “conflict minerals”, is now tentatively scheduled to be finalized sometime between January and June of 2012. The proposed rule was released in [...]
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European Sovereign Debt Exposures
The Securities and Exchange Commission’s Division of Corporate Finance issued Disclosure Guidance Topic number 4 on January 6, 2012 regarding European sovereign debt exposures. This guidance was precipitated by the inconsistent disclosure “in both substance and presentation” provided by registrants, both domestic and foreign private issuers. The Division of Corporate Finance was particularly concerned with [...]
Foreign Corrupt Practices Act Trends
Foreign Corrupt Practices Act Trends The Foreign Corrupt Practices Act (FCPA) has recently been in the news again. On December 13 the Securities and Exchange Commission filed a civil action in the Southern District of New York against seven former executives of Siemens AG for allegedly bribing senior government officials in Argentina. Also this month [...]
SEC Comment Letter Process Update
SEC Comment Letter Process Update The Securities and Exchange Commission released an update to their filing review process on December 1st. Beginning January 1, 2012, the staff will release the comment and response letters as early as 20 days following the completion of a filing review. This is down from the current 45 day policy. [...]
Say on Pay
Say on Pay The Dodd-Frank legislation required the implementation of say-on-pay or advisory votes on executive compensation for many companies in 2011. The legislation requires non-binding votes on the executive compensation packages at least every three years as well as a non-binding vote on how often the advisory votes are to be implemented with most [...]
