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PCAOB Reviews a Few Early CAMs

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The PCAOB announced it has conducted a limited review of audit reports of large accelerated filers reporting critical audit matters or CAMs. As a starting matter, the PCAOB’s report seems to implicitly and perhaps explicitly assume that its audit standard requiring the reporting of CAMs provides “more useful and timely... Read More

Topics: Public Companies and Securities

SEC Proposes Changes to Shareholder Proposal Rules and Rules Governing Proxy Advisors

At an open meeting on November 5th, SEC Commissioners voted 3-2 to propose potentially significant changes to the shareholder proposals process under Rule 14a-8 with respect to the bases upon which issuers can seek to omit shareholder proposal from their proxy materials. The proposed amendments to the shareholder proposal process... Read More

Topics: Public Companies and Securities

Enforcement Action Reveals Misleading Customer Counts

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In a settled enforcement action, the SEC resolved allegations related to non-monetary transactions regarding certain Comscore transactions.  The enforcement action also involved disclosures surrounding the number of customers. In 2014 and 2015, Comscore disclosed its total number of customers and net new customers added in quarterly earnings calls. Comscore also... Read More

Topics: Litigation, Public Companies and Securities

SEC Brings Enforcement Action for Loss Contingency Disclosure

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The SEC recently settled an enforcement action against Mylan N.V., claiming Mylan failed to timely disclose to investors a possible loss relating to a nearly two-year Department of Justice  probe into whether Mylan overcharged Medicaid by hundreds of millions of dollars for sales of EpiPen Auto-Injector by misclassifying EpiPen as... Read More

Topics: Litigation, Public Companies and Securities