Recently, the PCAOB proposed amendments to AS 6101, ‘Letters for Underwriters and Certain Other Requesting Parties,’ to address the limitations on an auditor’s ability to provide negative assurance in comfort letters. The proposal would modernize requirements that have remained largely unchanged since 2003. Comments are due by January 4th. Here are five things to know: 1. Accommodating Semiannual Reporting: Although the proposal was prompted in …
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This Thursday’s Webcast: “SEC Updates – Trending Topics in Disclosure”
Tune in this Thursday, November 12th for the webcast – “SEC Updates: Trending Topics in Disclosure” – during which Sarah Sellers and Asa Henin will provide an overview of trending topics, such as the use of AI or the effects of tariffs, and the evolving role they pose in related corporate governance and disclosure matters. Register now. We also have other webcasts coming up as part …
How Might the Midterms Impact You? 10 Questions to Ask
In the wake of the midterm elections, we at Cooley were talking yesterday about what it all might mean – and we came up with these ten questions for you to consider: General Trend Impacts:
What If an Investor Won’t Engage With You?
If you’re a smaller company – or even a larger company – perhaps some of your larger shareholders won’t get back to you when you reach out to them. Do you keep going back to them year after year? The answer is “yes,” particularly if you have a specific issue for which you need to engage. If it’s important to you, you need to make …
Another Dozen Things In-House Practitioners Are Saying About How AI Impacts Disclosure Practices
A few months ago, I shared a dozen anecdotes from in-house practitioners about “How much do you think AI will impact disclosure practices (including all the diligence leading up to making disclosure)?”Here is another dozen responses that I received:
Corp Extends Form S-3 Eligibility for Temporary Voluntary Filers; Revisiting a 30-Year Old Position
Recently, Corp Fin issued this no-action letter to Sumisho Air Lease Corporation – with assistance from Cooley’s JP Motley and Justin Kisner! – that updates and extends the framework established 30 years ago in Lamar Advertising governing Form S-3 eligibility during a short voluntary Exchange Act reporting period. The Staff also revised Securities Act Forms CFI Question 115.15 to note the Staff’s updated position and …
Upcoming Webcast: “SEC Updates – Trending Topics in Disclosure”
Tune in on Thursday, November 12th for the webcast – “SEC Updates: Trending Topics in Disclosure” – during which Sarah Sellers and Asa Henin will provide an overview of trending topics, such as the use of AI, the effects of tariffs and the evolving role they pose in related corporate governance and disclosure matters. Register now. We also have other webcasts coming up as part of …
Video Archive: “It’s Happening! How the SEC Proposals Will Impact You”
We have posted the video archive for the webcast – “It’s Happening! How the SEC Proposals Will Impact You” – during which Cooley’s Brad Goldberg, Justin Kisner and Michael Mencher addressed the practical implications of the many recent groundbreaking moves by the SEC…
SEC and Nasdaq Issue Tokenization FAQs
Recently, the SEC’s Division of Trading and Markets – which is the office that regulates TSVs – issued these four FAQs, which address: In addition, Nasdaq issued these FAQs – well, they’re called FAQs but they’re not in that format – that summarizes part of the SEC’s Order as well as notes other things including: 1. Lack of Interoperability: The SEC’s Innovation Exemption doesn’t require …
Glass Lewis Makes No Voting Policy Changes; ISS Solicits Comments
In a world where the only constant is change, it could have been surprising to see that Glass Lewis made no changes to its global voting policies for next year – except that Glass Lewis had announced last month – when it opened comment on the four perspectives that will underpin its research beginning next year – that there would be minimal changes to its …