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This week, the Securities and Exchange Commission’s 2026 rulemaking agenda (the “Unified Agenda”) was made publicly available (see here).  The Unified Agenda sets out the SEC’s rulemaking priorities for the next year, with general timeframes (but these timeframes are guidelines, and should not be considered definite indicators of when rulemakings will happen).  The current…

While visiting Texas, Securities and Exchange Commission Chair Atkins addressed corporate law matters and disclosure reform issues.  Here, we address the Chair’s comments related to disclosure reform.  Chair Atkins once again emphasized the need to return to principles of financial materiality when considering disclosure requirements.  He noted as well that disclosure requirements should be tailored…

Securities and Exchange Commission Chair Paul Atkins testified before the House Financial Services Committee and the Senate Committee on Banking, Housing, and Urban Affairs last week, presenting a comprehensive overview and update of the SEC’s priorities and initiatives. Consistent with his various remarks since the start of his tenure, Atkins’ remarks centered on capital formation…

On January 13, 2026, Securities and Exchange Commission Chair Atkins released a statement relating to a comprehensive review of Regulation S-K.  In the Chair’s statement, he notes that he has asked the Staff of the Division of Corporation Finance to “engage in a comprehensive review of Regulation S-K.”  The Chair notes that the first step…

Although it may seem early, it is already time to start preparing for the 2026 annual report and proxy season.  While many disclosure requirements remain consistent from prior years, there has been a significant shift in the focus of, and discourse relating to, the priorities of the Securities and Exchange Commission.  Practitioners started to see…

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The proxy and annual reporting season may seem a long way off. However, in light of the amount of work and planning that goes into the proxy statement, annual report, and annual meeting of shareholders, this is the ideal time to…

On August 26, 2025, the Securities and Exchange Commission’s Office of the Inspector General (“OIG”) issued a report entitled “Improved Documentation and Guidance Can Help Strengthen Corporation Finance’s Disclosure Review Program.”  By way of background, the Disclosure Review Program (the “DRP”) forms the backbone of the Division of Corporation Finance’s work, and consists of the…

On September 4, 2025, the Securities and Exchange Commission’s spring 2025 rulemaking agenda (the “Agenda”) was made publicly available (see here).  Chairman Paul Atkins previewed the Agenda, which widely diverges from the Commission’s fall 2024 rulemaking agenda, in a simultaneously-released statement (the “Statement”), declaring that “[t]he items on the agenda represent the Commission’s renewed…