Last week, the Securities and Exchange Commission adopted a rule under which any issuer can “test the waters” for a securities offering before or after filing a registration statement. This new rule extends an accommodation previously available only to emerging growth companies. Please click here to read the full alert memorandum.…

Earlier this week, the SEC published a release requesting comment on the quarterly reporting system.  The release is thoughtful and concise, but it mostly asks questions, so it provides little indication of what action the agency might consider taking. Two major flaws are regularly attributed to the reporting practices of public companies: complexity and short-termism.  The release engages with these criticisms, but we doubt this is the start of a process that will eventually result…