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SEC Commissioner Peirce Dissents from Rules on Cybersecurity Disclosure

Reynolds Holding

Cyber risk and the attendant disclosure obligations have been front-and-center for public companies for a long time, and the SEC has underscored the importance of cyber disclosures. 10] The Commission proclaims its “indifference” to companies’ cyber practices, [11] and the final rule is slimmer in detail than the proposed rule.

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Is It the End of Entire Fairness as We Know It?

Reynolds Holding

It is this body of law that distinguishes Delaware and has elevated it among all other jurisdictions as a preeminent forum for business entity formation and business dispute resolution. Lynch Communication Systems, Inc., Synutra International, Inc. 272, 1993, opinion (Del. Corwin, et al.

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SEC Announces Enforcement Results for FY 2022

Reynolds Holding

A hallmark of the Enforcement Program in fiscal year 2022 was robust enforcement through resolutions that imposed penalties designed to deter future violations, establish accountability from major institutions, and order tailored undertakings that provide potential roadmaps for compliance by other firms. billion, including a record $4.2

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SEC Commissioner Speaks on Shareholder Proposals, Proxy Statements, and Rule 14a-8

Reynolds Holding

4] It started with allowing Whole Foods to exclude a proxy access proposal pursuant to paragraph (i)(9) for conflicts with the company’s proposal, [5] only for the Commission staff to change its mind six weeks later and state that it would express no view on paragraph (i)(9) for the Whole Foods proposal and for the remainder of the season. [6]