Dodd-Frank.com

Be Careful What You Tell the Rating Agencies – Regulation FD Revised

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This SEC revised Regulation FD to implement Section 939B of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which requires that the SEC amend Regulation FD to remove the specific exemption from the rule for disclosures made to nationally recognized statistical rating organizations and credit rating agencies... Read More

Topics: Banking, Insurance, Public Companies and Securities

PCAOB, GAAS and Broker-Dealers

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The SEC has issued interpretive guidance regarding the meaning of the term “generally accepted auditing standards” (“GAAS”) after adoption of the Dodd-Frank Act.  Section 982 of the Dodd-Frank Act amended the Sarbanes-Oxley Act of 2002  to authorize the Public Company Accounting Oversight Board (“PCAOB”), among other things, to establish, subject... Read More

Topics: Banking, Public Companies and Securities

More 14a-11 Examples

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Filings by public companies continue to include references to Rule 14a-11, which permits shareholders to nominate a director and include the nomination in the registrant’s proxy statement.  In the last several days we have noted the following:  LAM Research Proxy (filed September 13, 2010)  Proposals Submitted under SEC Rules. Stockholder-initiated... Read More

Topics: Public Companies and Securities

SEC Proposes Rules on Window Dressing

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The SEC issued proposed rules on short-term borrowing disclosures.  Separately, the SEC issued an interpretive release on the presentation of liquidity and capital resource disclosures in MD&A disclosures.  The interpretive release will be effective upon publication in the Federal Register.  This rule making was not required by the Dodd-Frank Act... Read More

Topics: Banking, Insurance, Public Companies and Securities