On December 15, 2025, Nasdaq submitted a proposed rule change to the Securities and Exchange Commission (the “SEC”) seeking approval to expand significantly its equity trading hours. If approved, the change would allow trading in Nasdaq-listed equity securities and exchange-traded products for 23 hours per weekday, representing a notable shift in U.S. equity market structure.
Nasdaq Proposes Expanded Discretion to Deny Initial Listings on Public Interest Grounds
On December 12, 2025, The Nasdaq Stock Market LLC (“Nasdaq”) filed a proposed rule change with the Securities and Exchange Commission (“SEC”) that would expand Nasdaq’s authority to deny initial listing, even when an issuer satisfies all applicable quantitative and corporate governance listing requirements. Nasdaq states that the proposal is intended to support meaningful listing
SEC Approves Nasdaq Proposal to Amend Initial Listing Requirements for de-SPAC Transactions
On December 8, 2025, the Securities and Exchange Commission (“SEC”) approved proposed rule changes submitted by The Nasdaq Stock Market LLC (“Nasdaq”) that exempt certain over-the-counter (“OTC”)-traded SPACs from the reverse merger rule and minimum average daily trading volume requirements. Citing a recent increase in the number of SPACs that were listed at the time
Nasdaq Releases Policy Recommendations to Promote Capital Formation
In March 2025, Nasdaq released a comprehensive set of policy recommendations intended to advance capital formation in a paper titled “Advancing the U.S. Public Markets: Unlocking Capital Formation for a Stronger American Economy.” The paper outlines three key sets of policy reforms, which were prepared by Nasdaq in dialogue with industry stakeholders, including
Nasdaq Proposes to Tighten Non-Compliance Period
On June 21, 2024, The Nasdaq Stock Exchange (“Nasdaq”) filed a proposed rule change with the Securities and Exchange Commission to modify the application of the bid price compliance period as a result of which a company takes action that causes non-compliance with another listing requirement. Companies that have equity securities with low trading prices
Enforcement of Dodd-Frank Clawback Policies Under Foreign Law
In October 2022, the SEC adopted Rule 10D-1, directing national securities exchanges to establish listing standards that prohibit the listing of any security of a company that does not adopt and implement a written policy requiring the recovery, or “clawback,” of certain erroneously paid incentive-based executive compensation. In this Legal Update, we discuss the application
SEC Approves Dodd-Frank Clawback Listing Standards with October 2, 2023 Effective Date
On June 9, 2023, the US Securities and Exchange Commission (“SEC”) approved the clawback listing standards proposed by the New York Stock Exchange (“NYSE”) and The Nasdaq Stock Market (“Nasdaq”), each as required by SEC Rule 10D-1 in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Earlier in June 2023, both the
NYSE and NASDAQ Propose October 2, 2023 Effective Date to Clawback Listing Standards
On June 5, 2023, the New York Stock Exchange (“NYSE”) filed an amendment to its proposed Dodd-Frank clawback listing policy providing for an effective date of October 2, 2023. Similarly, on June 6, 2023, Nasdaq filed an amendment proposing an October 2, 2023 effective date for its Dodd-Frank clawback listing standards. If the US Securities
Nasdaq Bank Webinar Series: Corporate Governance – Board Oversight, Risk Mitigation & D&O Strategies
MB Microtalk: Changes to Direct Listing Rules
In this MB Microtalk video, Mayer Brown partner, Brian Hirshberg, discusses the recent amendments to each of the NYSE and the Nasdaq direct listing rules, which are designed to increase pricing flexibility and allow direct listings to be a more viable alternative for companies going forward.
Visit our MB Microtalk page for more topics