I thought this note from the “Small Business Institute” had some good disclosure advice: “Business performance is not linear and is often challenging to forecast. Every public company is going to have bad news periodically. It is a certainty, and…
One challenge that sometimes happens as part of a company’s drafting process is when the compensation group is working off kilter a little bit from the rest of the drafting team.
The problem arises due to a timing difference. The…
I thought this note from the “Small Business Institute” had some good disclosure advice: “Business performance is not linear and is often challenging to forecast. Every public company is going to have bad news periodically. It is a certainty, and…
It can be disheartening to know that you spend much of your career drafting disclosure that few wind up reading. To some extent, AI will change this – as AI agents are happy to read your disclosures without falling asleep.…
In this memo, Pay Governance examines comment letters from investors that were submitted to the SEC in response to the agency’s proposed expansion of Non-Accelerated Filer status and Emerging Growth Company accommodations, along with submissions related to the SEC’s Executive…
As part of our blog series based on this great panel – featuring WilmerHale’s Lily Brown and Edward Jones’ Keir Gumbs – here’s a blog that addresses the question of: “When you are in charge of a disclosure team, what…
If you’ve been following the nifty “comment letter tracker” for the SEC’s semiannual reporting proposal put together by Professor Tzachi Zach, you can see that the number of comments are very high – and that a large percentage of comment…
This paper by Professors Jonathan Macey and Nathan Atkinson – “Mirroring The Market: Passive Voting And Outcome Non-Neutrality” – argues that current mirror-voting proposals are not truly neutral. Uniform mirroring inadvertently lowers voting thresholds and subsidizes quorums. The authors propose…
