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On September 10, 2012, in response to market uncertainty, the CFTC issued FAQs clarifying the timing of swap dealer registration. The guidance confirms that entities will not be deemed to...
The recently enacted Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Act”) strengthens existing sanctions on Iran, especially those aimed at third-country nationals eng...
In July we discussed the prospect of two proxy access shareholder proposals coming up for vote this summer, first at Forest Labs and then Medtronic. Both were generated by the form develo...
On August 10, 2012, President Obama signed into law the Iran Threat Reduction and Syria Human Rights Act of 2012 (Public Law 112-158 — the “Act”). The Act strengthens existing sanct...
Since our last blog post on say-on-pay litigation in January 2012, there have been several dismissals of say-on-pay lawsuits on procedural grounds – principally the failure of plaintiff...
In this Report:
As of September 4, 2012, a total of 237 Dodd-Frank rulemaking requirement deadlines have passed. Of these 237 passed deadlines, 145 (61.2%) have been missed and 92 (38...
On August 29, 2012, the Securities and Exchange Commission (“SEC”) issued a proposal to permit widespread advertising and other forms of “general solicitation” in private offering...
A recent press release from the Shareholder Rights Project (SRP), issued jointly with the Massachusetts Pension Reserves Investment Management Board, indicates that they have been working...
On August 22, 2012, the National Futures Association (“NFA”) filed proposed rule changes with the Commodity Futures Trading Commission (“CFTC”) that will require futures commissio...
On August 22, 2012, the SEC staff released Frequently Asked Questions (“FAQs”) about certain JOBS Act provisions that address the conduct of research analysts and the publication of r...