Hema Gharia

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Speaking at the Society for Corporate Governance Conference in Nashville earlier this month, Securities and Exchange Commission (“SEC”) Chair Paul Atkins addressed two major themes for public companies:  restoring materiality as the foundation of public company disclosure and reconsidering the shareholder proposal process under Rule 14a-8.  Chair Atkins connected those themes to the SEC’s broader…

On July 11, 2025, the staff (the “Staff”) of the U.S. Securities and Exchange Commission’s (the “SEC”) Division of Corporation Finance (the “Division”) published non-substantive updates to various Compliance and Disclosure Interpretations (“CDIs”) relating to Exchange Act Sections 13(d) and 13(g) and Regulation 13D-G Beneficial Ownership Reporting. 

The updates bring the CDIs into alignment with…

On February 12, 2025, the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission issued Staff Legal Bulletin No. 14M (“SLB 14M”), which rescinds in part Staff Legal Bulletin No. 14L (“SLB 14L”). In addition, SLB 14M provides guidance and clarification on the Staff’s views on the scope…