Reynolds Holding

MAY 25, 2023

Can the tone or sentiment of an SEC comment letter provide a signal to investors about the quality of an underlying firm? 1] My study, though still at a preliminary stage, suggests an intriguing relationship between the sentiment expressed in SEC staff comment letters and the likelihood of qualification for proposed Reg A offerings.

Compliance 52

Compliance Finance 52

Reynolds Holding

JULY 23, 2023

During the filing review process, the SEC will issue comment letters to firms whose disclosures are inconsistent with applicable SEC reporting requirements or “materially deficient in explanation or clarity” (SEC 2019b). We examine all SEC comment letters referencing a firm’s earnings conference call(s).

Compliance 52

Compliance Corporate Finance Marketability Finance 52

Reynolds Holding

APRIL 3, 2024

1] This guidance is not promulgated through notice-and-comment rulemaking, but appears in staff statements and speeches, phone calls, some types of no-action letters, and the like. As we often point out, tone from the top matters. Some of this guidance is found only in the high-priced whispers of a select few attorneys or auditors.

Start-ups 45

Start-ups Banking Marketability Compliance 45

Reynolds Holding

JUNE 27, 2023

The opposition statement may take a tone very different from the negotiation discussions, and requiring it to be sent in the middle of negotiations may disrupt the dynamics and process. 1, 2022) (“During the 2022 proxy season, the [s]taff essentially overturned long-standing no-action letter precedent. See supra note 14. [16]

Corporate Finance 45

Corporate Finance Marketability Finance Start-ups 45

Harvard Corporate Governance

OCTOBER 5, 2022

The SEC’s oversight of publicly-traded firms includes both routine monitoring through comment letter reviews of firm’s reporting compliance and pursuing enforcement actions against firms if their public reporting is deficient. Our empirical analysis reveals two main sets of findings.

Compliance 219

Compliance Finance Marketability 219

Reynolds Holding

SEPTEMBER 11, 2023

But they do impose substantial new and detailed quarterly reporting requirements, two prohibitions and many new disclosure requirements for side letters and expense allocations, and restrict certain other activities,which the SEC explicitly warned that Exam and Enforcement Staff will be closely reviewing. The SEC is Preparing to Litigate.

Compliance 40

Compliance Marketability Start-ups Banking 40