Public Companies

On May 19, 2026, the Securities and Exchange Commission (SEC) proposed significant amendments to the public company reporting framework that would simplify the current filer status regime and substantially expand the availability of scaled disclosure accommodations. The current framework requires companies to annually reevaluate their filer status (large accelerated filer, accelerated filer, non-accelerated filer) and…

On May 19, 2026, the Securities and Exchange Commission (SEC) proposed a sweeping set of rule and form amendments intended to modernize and simplify the registered securities offering process for public companies, registered closed-end funds (RCEFs), business development companies (BDCs), and other products. The proposal, if adopted, would be the most significant update to the…

The SEC is reported to be planning to issue rule proposals creating a regulatory framework for trading of tokenized, digital securities of publicly-traded companies that are issued by third parties unaffiliated with the issuer.  The tokens would be similar to “phantom stock,” representing digital representations of the securities, but would have no equity or voting…

On May 5, 2026, the SEC proposed to permit public companies to file semiannual reports instead of quarterly reports. If adopted, companies subject to Exchange Act Section 13(a) or 15(d) that currently file quarterly reports on Form 10-Q could elect to file one semiannual report on new Form 10-S and one annual report on Form…

On April 16, 2026, the SEC’s Division of Corporation Finance issued an exemptive order permitting certain tender offers for equity securities to remain open for as few as 10 business days rather than the current 20-business-day minimum under Exchange Act Rules 13e-4(f)(1)(i) and 14e-1(a). The Division said the relief is intended to address market inefficiencies…

In our February 20, 2026 client alert titled “New Reporting Obligations for Directors and Officers of Foreign Private Issuers,” we outlined the Holding Foreign Insiders Accountable Act (HFIAA) and the new reporting requirements under Section 16(a) of the Exchange Act for the officers and directors of foreign private issuers (“FPIs”) registered with the…

Legislation that will subject non-US companies that publicly report in the U.S. to short-swing profits liability rules under Section 16 of the Exchange Act is embedded in the annual defense funding bill that has passed in the House and goes to the Senate as early as next week.  The requirement would apply to companies that…

Glass Lewis, one of the two large proxy advisory firms to institutional investors, announced earlier this month that it would no longer employ standardized “benchmark” voting policies, but instead customize policies on a client-by-client basis.  It explained the shift by citing “[r]apid advances in technology, especially AI, that are enabling highly customized approaches to voting,”…

As of 12:01 am on October 1, 2025, congressionally appropriated funding lapsed for most operations of the United States government. Though the government has shut down, business continues, and market participants that need to interact with the Securities and Exchange Commission (the “SEC”) in order to complete a transaction may encounter delays. Below is a…