New SEC staff guidance published this month indicates a more nuanced and sophisticated view of non-GAAP measures than has tended to apply since Regulation G was enacted in 2003. New Compl...
Today, the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission issued a no-action letter to Davis Polk, Cleary Gottlieb and O’Melven...
Yesterday, the SEC issued a proposal that would amend Rule 163 of the Securities Act to allow underwriters or dealers, acting on behalf of well-known seasoned issuers (WKSIs), to offer se...
WHILE THE PUNDITS are declaring that the recession is over and the financial crisis has been abated, part of the aftermath is the continuing demand for corporate governance reforms by Con...
The U.S. IPO market, which has been in the doldrums since 2007, has recently been showing signs of life. We have recently completed several large transactions, and our pipeline of deals i...
A company that has been subject to SEC reporting obligations for fewer than three years, that has less than $150 million in public float, or that is affiliated with a broker-dealer, gener...
In August 2006, the SEC published its final release to completely overhaul the rules and regulations for executive compensation disclosure, which was met with intense debate and focus. Al...
After a year of proposed rulemaking, the US Securities and Exchange Commission (SEC) recently finalized the first amendments to its reserves and other reporting requirements for the oil a...
Due to continuing equity market turmoil, many companies are at risk of losing the ability to issue securities off of an automatic shelf registration statement. When a company files its an...
In the last several years, there have been a number of situations where issuers have failed to file reports with the SEC on a timely basis and bondholders alleged that such failure violat...
