The SEC’s Division of Corporation Finance today published five new Compliance and Disclosure Interpretations, or “C&DIs,” all concerning Item 1.05 of Exchange Act Form 8-K, Disclosure of Cybersecurity Incidents.

New C&DI 104B.05 describes a ransomware attack on a public company ended by a payment to the threat actor before any materiality evaluation of the incident.

The SEC today paused implementation of the climate rules the agency rolled out less than one month ago, in the face of significant legal challenges in numerous federal lawsuits.  The rules would impose substantial disclosure mandates on companies, including concerning the costs of extreme weather events, corporate strategies for addressing climate change, corporate governance procedures

Climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating from numerous governmental authorities and non-governmental organizations (NGOs) in recent years. Mayer Brown lawyers from around the world produced a White Paper on Global Climate Change Disclosure Initiatives and Board Corporate Governance Considerations

All across the world, climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating this past year from numerous governmental authorities and non-governmental organizations.

At Mayer Brown, I had the honor of leading a group of 21 partners from across 14 of the

Lawrence A. Cunningham & Bill Hayes

The SEC’s climate disclosure rule will have obvious and enormous impacts on company disclosure teams, including lawyers, accountants, and compliance personnel. What about boards of directors?  The Editor of Directors & Boards magazine, Bill Hayes, recently opened that topic with Mayer Brown’s Lawrence Cunningham, who has been closely involved

April 3, 2024 Webinar
1:00 p.m. – 2:00 p.m. EST
Register here.

After much anticipation, on March 6, 2024, the US Securities and Exchange Commission voted to adopt final rules that require reporting by public companies of climate change-related disclosure. While the final rules differ from the SEC’s controversial proposed rules in significant ways

The Securities and Exchange Commission (the “SEC”) has adopted new rules that require public companies to disclose substantial information about the material impacts of climate-related risks on their business, financial condition, and governance (the “Final Rules”).  The SEC says that “climate-related risks, their impacts, and a public company’s response to those risks can significantly affect

The Securities and Exchange Commission adopted (in a 3-2 vote) final rules requiring disclosures about the material impacts of climate-related risks on their business, financial condition, and governance.

These rules had first been proposed in March 2022.  The SEC adopted the final rules after considering, over a two-year period, some 4,500 unique comment letters from

In the past year, Mayer Brown’s Larry Cunningham has twice testified before Congress on aspects of corporate governance and securities disclosure, along with co-authoring several comment letters on such topics as the SEC’s climate disclosure proposal and the FDIC’s corporate governance proposal.  Most recently, his written testimony from last month’s hearing on oversight of the