In a significant and welcome change from the SEC’s proposal, the agency will not mandate cooling-off periods for 10b5-1 plans used for corporate stock buybacks. For plan use by director...
Our 2022 IPO corporate governance survey reviews governance structures at the time of the IPO for the largest U.S.-listed IPOs of “controlled” and non-“controlled” companies betwe...
Webinar
1.0 CA - General; NY - Professional Practice / Practice Management
We invite you to watch a Davis Polk webinar on the SEC’s new pay versus performance rule. Now that companies have started putting pen to paper on the required pay versus performance dis...
The SEC adopted the final “clawback rule” mandated by the Dodd-Frank Act requiring public companies to establish and enforce policies to recover excess incentive compensation from exe...
A federal district court decision involving alleged Regulation FD violations highlighted analysis of key elements governing the regulation relating to whether information is material and ...
We consider the practical takeaways of new SEC Rule 14a-19 and universal proxy card voting in contested director elections. The change to universal proxy cards is a prompt for companies t...
The SEC adopted the final rule implementing the “pay versus performance” disclosure requirement mandated by the Dodd-Frank Act, which is broader in scope than the 2015 proposed rule a...
The proposal would significantly narrow the likelihood of obtaining no-action relief from the SEC on shareholder proposals, leading to a potential flood of additional proposals on ballots.
On June 8, 2022, the SEC requested comments for the third time on its proposed clawback rule, which is required to be promulgated under the Dodd-Frank Act. As part of this reopening, the ...
