On September 8, 2014, the Securities and Exchange Commission (“SEC”) proposed a rule to permanently exempt the publication or distribution of certain security-based swap price quotes ...
Over the past 18 months companies have scoured their supply chains and wrestled with hard-to-interpret regulatory mandates in order to comply with the initial reporting deadline for the S...
Today the SEC issued a stay of the conflict minerals rule – but the stay extends only to “the effective date for compliance with those portions of Rule 13p-1 and Form SD that would re...
The SEC staff has responded to the D.C. Circuit Court of Appeals’ April 14 decision, which found a key feature of the conflict minerals rule in violation of constitutional free-speech g...
The D.C. Circuit Court of Appeals issued an opinion today in the ongoing challenge to the SEC’s conflict minerals rule, holding that the rule violates the free-speech guarantee of the F...
The SEC’s Division of Trading and Markets recently issued an important No-Action Letter that effectively permits “M&A Brokers” to advise on and arrange certain securities transactio...
At the recent Securities Regulation Institute, Keith Higgins, the head of the SEC Division of Corporation Finance, indicated that the SEC staff will be looking for less detailed disclosur...
Amid the recent uptick in U.S. IPO transactions to levels not seen since the heady days of 1999 and 2000, Davis Polk’s pipeline of deals remains robust, leading us to believe that stren...
A nonpublic company seeking access to the capital markets faces a largely binary choice between conducting a private placement, with few if any reporting obligations afterwards, and condu...
Today the public comment period ended for two proposals by the Public Company Accounting Oversight Board that we believe could dramatically increase the scope, length, cost and complexity...
