On May 25, 2023, the staff of the US Securities and Exchange Commission’s Division of Corporation Finance released three Compliance and Disclosure Interpretations (“C&DIs”) on the recent amendments to Rule 10b5-1 regarding insider trading arrangements and related disclosures. Specifically, C&DIs 120.26 and 120.27 identify the dates by which companies must first include the new disclosures
Insider Trading Rule Amendments Now in Effect
- add new conditions to the affirmative defenses to address concerns regarding the use of material nonpublic
Clawback Rule Guidance
In our prior posts, we discussed the Securities and Exchange Commission’s adoption of Rule 10D-1 that directs the securities exchanges to establish listing standards prohibiting the listing of a security of any company that fails to adopt and implement a clawback policy.
The Staff of the Division of Corporation Finance has issued Compliance and
Across the (Company) Board
Mayer Brown’s newest resource, Across the Board™, provides private and public companies and their boards with the latest updates, alerts, and resources in one convenient place.
Lawyers in our Public Companies & Corporate Governance practice advise companies on transactional, regulatory, governance, and litigation matters.
Read new spotlight article by Larry Cunningham, CEO Comments on