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The Proposed SEC Climate Disclosure Rule: A Comment from Shivaram Rajgopal

Harvard Corporate Governance

Compliance costs are not a significant portion of market capitalization. On page 390 of the proposal, the SEC estimates costs in the first year of compliance to be around $640,000 and annual costs in subsequent years to be $530,000 for larger companies. Let us start with the costs.

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ISS Discusses Wells Fargo’s Historic $1 Billion Settlement With Investors

Reynolds Holding

After a decades-long history of “reckless” and “unsound” practices, federal regulators imposed punitive consent orders on Wells Fargo, requiring the bank to implement a three-stage compliance and corporate oversight overhaul. The OCC and CFPB’s decrees also provided detailed three-stage “action plans” for compliance.

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To Whom Are Caremark Duties Owed?

Reynolds Holding

Plaintiff’s shares are worth approximately $6,000 of a company with a market capitalization of more than $121 billion. Furthermore, Plaintiff owns only 56 shares of approximately 1.15 billion outstanding shares of Starbucks stock.

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AuditBoard Appoints Accomplished SaaS Executive Roxanne Oulman to Board of Directors

Audit Board

Prior to that, as EVP and CFO of CallidusCloud, she was instrumental in driving the growth of the company’s market capitalization from $350 million to $2.4 Medallia was publicly traded (NYSE: MDLA) until its purchase by Thoma Bravo for $6.4B in October of 2021. billion, and led diligence efforts for its sale to SAP.

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Skadden Discusses New SEC Pay-Versus-Performance Compliance & Disclosure Interpretations

Reynolds Holding

On November 21, 2023, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued eight new Compliance & Disclosure Interpretations (C&DIs), and revised two previously issued C&DIs, relating to the final pay-versus-performance (PVP) disclosure rules adopted last year. Answer: Yes.

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Olshan Discusses FINRA, Stock Exchange Crack Down on Small-Cap IPO “Ramp and Dump” Schemes

Reynolds Holding

Although FINRA states that its Regulatory Notice does not create new legal or regulatory requirements or new interpretations of existing requirements, it squarely places the obligation to battle such schemes on underwriters as “gatekeepers to the public markets.” broker-dealers to the U.S.

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Unpacking the SEC’s Climate-Related Disclosures: A Quick Tour of the Issues

Reynolds Holding

In this light, the SEC has proposed several “accommodations” with respect to Scope 3 disclosures, including (i) a special safe harbor from liability, (ii) an exemption for smaller reporting companies, (iii) delayed compliance dates for Scope 3 emissions disclosure, and (iv) different “attestation” standards for Scope 3 data.