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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: No.

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Cooley’s 2023 Activism Year in Review: Wolfpacks at the Gate

Cooley M&A

Activist target profile: Top flags for tech and healthcare companies Activists are stock pickers – generally building a position at a target company only if they can drive meaningful risk-adjusted returns. Promoting director share ownership where possible, including through open market director purchases.