On August 31, 2026, the Securities and Exchange Commission announced that it entered into a Memorandum of Understanding (“MOU”) with the Food and Drug Administration (“FDA”) to create a framework to support the exchange of information between the two agencies regarding FDA-regulated products and activities. The MOU is designed to enhance both agencies’ ability to
Ali Perry
SEC Filing Fees are Decreasing to $87.00 per million dollars!
On August 21, 2026, the Securities and Exchange Commission (“SEC”) announced that the filing fee rate for securities registration will be decreasing from $138.10 per million dollars to $87.00 per million dollars, effective October 1, 2026. This is the second consecutive year that the filing fee has decreased in recent years.
The SEC filing fee…
FASB Proposes New Guidance on Stablecoin Classification as Cash Equivalents and Enhanced Disclosure Requirements
On August 18, 2026, the Financial Accounting Standards Board (“FASB”) issued a proposed accounting standards update (“ASU”) titled Statement of Cash Flows (Topic 230): Cash Equivalents—Disclosure Enhancement and Evaluation of Certain Digital Assets. The proposed ASU seeks to clarify whether certain digital assets meet the definition of “cash equivalents” on the balance sheet, and to…
NYSE Proposes Extending Internal Audit Function Transition Period from One Year to Five Years
On August 13, 2026, the Securities and Exchange Commission (“SEC”) published notice of a proposed rule change (SR-NYSE-2026-37) by the New York Stock Exchange (“NYSE”) to amend Sections 303A.00 and 303A.07 of the NYSE Listed Company Manual to extend the transition period in which a newly listed company must establish an internal audit…
SEC Stays Nasdaq’s New $5 Million MVLS Listing Standard Pending Commission Review
On July 29, 2026, the Securities and Exchange Commission (“SEC”) announced that it stayed its July 22, 2026 order (Release No. 34-105971) approving The Nasdaq Stock Market LLC’s (“Nasdaq’s”) rule proposal to adopt a new continued listing standard requiring listed companies to maintain a minimum Market Value of Listed Securities (“MVLS”) of at…
ESG and Anti-ESG Shareholder Proposals in 2026
In many ways, the 2026 proxy season has been markedly different than prior seasons, due, in no small part, to the November 2025 decision by the U.S. Securities and Exchange Commission (“SEC”) Staff not to provide substantive guidance on the grounds on which a company could omit a shareholder proposal under most prongs of Rule…
The 2026 Proxy Season: Shareholder Proposal Trends
The 2026 proxy season thus far has been out-of-the-ordinary, impacted by regulatory and policy developments that required companies and shareholders to adapt their shareholder proposal and engagement strategies. As a result of these unusual circumstances, particularly when coupled with uncertainty about the evolving role of the Securities and Exchange Commission (“SEC”) and potential rule changes…
SEC Proposes Rules Simplifying Filer Status Determinations and Increasing Disclosure Accommodations
On May 19, 2026, the U.S. Securities and Exchange Commission (the “SEC”) published two rulemaking proposals, each of which would substantially revise the requirements of the U.S. federal securities laws applicable to public companies. These proposals mark the next step in SEC Chair Paul Atkins’ mission to grow the U.S. capital markets and “make IPOs…
EDGAR Next and Exchange Delegation: A New Compliance Consideration for Listed Companies
On January 27, 2026, the New York Stock Exchange (“NYSE”) issued its annual listed company guidance, highlighting an important but often overlooked consequence of the Securities and Exchange Commission’s (“SEC”) transition to EDGAR Next: the need for listed companies to add their exchange as a “delegated entity” on the EDGAR Next platform.
Background on…
Section 16(a) Reporting for Foreign Private Issuers
Effective March 18, 2026, foreign private issuers, or FPIs, will be subject to the reporting requirements under Section 16(a) of the Securities Exchange Act of 1934. Below, we outline what this means for FPIs, their officer and directors, and how you can get ready to comply.
What are Foreign Private Issuers?
FPIs are non-U.S. companies…
