Given the heightened interest in the SEC’s proposed rule on climate, in a series of two blogs, I’m covering the nuts & bolts of sending in a comment letter to the SEC about a proposed rule. My first blog covered
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How to Write a Comment Letter to the SEC on a Rulemaking: The Mechanics
Given the heightened interest in the SEC’s proposed rule on climate, in a series of two blogs, I’ll be covering the nuts & bolts of sending in a comment letter to the SEC about a proposed rule.
This first blog…
Internal Investigations: Who Are the Company’s Actual Adversaries?
Following up on our recent blog in a series about internal investigations, investigative attorneys are often engaged, at least in part, for the very purpose of establishing legal privilege over an internal investigation. In other words, they are paid to…
In-House Corner: Rule 10b5-1 Plans
This feature of our blog is where our in-house readers share tips, anecdotes and thoughts about things that come up in their daily practice. This particular batch of thoughts is about handling Rule 10b5-1 plans [feel free to ping me…
Spring Cleaning: Dissolve Unnecessary Subsidiaries
Following up on my blog entitled “7 Rules of Thumb for Subsidiary Governance,” on your annual calendar of “to-do” governance tasks, you should include a check-in as to whether you have any subsidiaries that have remained dormant for…
Our New Guide: “The SEC’s Climate Disclosure Proposal – A Comprehensive Look”
Allison Handy and I have put together this 19-page guide entitled “The SEC’s Climate Disclosure Proposal: A Comprehensive Look.” Interestingly, the SEC has updated its proposing release several times since it was first posted – so the proposing release has…
Internal Investigations: Law on Work Product & Attorney-Client Privilege
Following up on our recent blog in a series about internal investigations, note that Federal Rule of Evidence 502(g) states:
(1) “Attorney-client privilege” means the protection that applicable law provides for confidential attorney-client communications; and
(2) “Work-product protection” means the…
“SEC Proposes New Cybersecurity Disclosure Rules”
I’m excited to share our firm memo – “SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance” – authored by Valerie Dahiya and David Aaron. Check it out!
Also check out this blog…
The SEC’s Climate Proposal: Board Oversight
Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about a board’s oversight of climate-related matters. For some companies, this type of disclosure undoubtedly would impact how much time and resources they…
The SEC’s Climate Proposal: Disclosing Targets & Goals
Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about a company’s climate targets and goals – for those companies that have done that sort of thing.
We have blogged before about…