On April 26, 2023, the U.S. Securities and Exchange Commission (SEC) published a notice of an open meeting to be held next Wednesday, May 3, 2023, to consider whether to adopt rules requiring additional disclosures relating to issuers’ equity share repurchases.

The SEC proposed the share repurchase disclosure rules back

Continue Reading Share Repurchase Disclosure Rules on SEC Agenda for May 3

On April 24, 2023, the U.S. Securities and Exchange Commission (SEC) extended the time period for its review and approval of the clawback-related listing standards from April 27, 2023 to June 11, 2023 (here and here).

As discussed in our previous blog post, Rule 10D-1 of the

Continue Reading SEC Extends Time for Review of NYSE and Nasdaq Clawback-Related Listing Standards

On April 17, 2023, S&P Dow Jones Indices (S&P DJI) announced a major change to its inclusion criteria. Effective immediately, all companies with multi-class share structures will be eligible for inclusion in the S&P 1500 Composite and its component indices, which include the S&P 500, S&P MidCap 400, and S&P

Continue Reading S&P Dow Jones Indices Opens Door for Multi-Class Share Companies

Our recent Client Alert discusses the SEC’s latest enforcement action against an IT services provider for alleged violations of Regulation G and other federal securities laws in its reporting and disclosure of non-GAAP financial performance measures. Without admitting or denying the findings in the SEC’s order, the company agreed

Continue Reading Continued SEC Scrutiny of Non-GAAP Disclosures

Our recent Client Alert discusses an important ruling issued by Vice Chancellor J. Travis Laster of the Delaware Court of Chancery on March 29, 2023. This ruling concluded that two companies with multiple classes of common stock were not required, under the Delaware statute, to obtain separate class votes of

Continue Reading Delaware Court of Chancery Issues Important Ruling for Multi-Class Companies Addressing Class Votes

Our Client Alert discusses the Delaware Court of Chancery’s recent issuance of a rare post-trial decision finding a CEO personally liable for millions of dollars in damages for breaching his fiduciary duties by tilting his company’s sale process in favor of his preferred acquiror and failing to disclose material facts about the sale process. Equally unusual, the Court of Chancery found the acquiror liable for monetary damages, on a joint basis with the CEO, for aiding and abetting the CEO’s breaches of fiduciary duty in providing inadequate disclosures to stockholders. The decision provides valuable insight into what Delaware courts expect of management and a board when selling a company, as well as the risks that can arise when a court determines that a sale process and related disclosures were improper.Continue Reading In Rare Decision, Delaware Court of Chancery Imposes Liability on CEO and Acquiror Post-Trial

In August 2021, the U.S. Securities and Exchange Commission (SEC) approved new board diversity listing standards for companies listed on The Nasdaq Stock Market LLC (Nasdaq). As part of these new listing standards, Nasdaq Rule 5606 now requires listed companies to annually disclose aggregated statistical information about the board’s self-identified

Continue Reading Considerations in Complying with Nasdaq Rule 5606

Wilson Sonsini is closely monitoring the fast-moving developments related to the recent closure of Silicon Valley Bank (SVB), including the press release issued on March 13, 2023, by the Federal Deposit Insurance Corporation (FDIC), FDIC Acts to Protect All Depositors of the former Silicon Valley Bank, Santa Clara, California.

Continue Reading Silicon Valley Bank Developments

Our timely client alert discusses the impact (or lack thereof) of impending amendments to Rule 10b5-1 on issuer structured share buy-back arrangements, such as accelerated share repurchases (ASRs). Final Rule 10b5-1 amendments, discussed comprehensively in our previous client alert, become effective on February 27, 2023. Stay tuned for further

Continue Reading Rule 10b5-1 Amendments Spare Issuer Accelerated Share Repurchases (ASRs)