All posts by Cydney Posner

SEC finally speaks on conflict minerals decision

by Cydney Posner The SEC has finally issued some guidance in light of the decision of the D.C. Circuit on the conflict minerals case.  In essence, the SEC has fashioned a modified rule that requires companies to make the mandated filing on a timely basis without including a statement as […]

WSJ reports SEC preparing to implement almost all of conflict minerals rule

by Cydney Posner As noted in this morning’s blog, the WSJ  is reporting that the SEC is “preparing to implement the bulk of a ‘conflict minerals’ rule this spring despite a U.S. court ruling that struck down a core provision on free-speech grounds, according to a person familiar with […]

Two SEC Commissioners Speak Their Minds About Conflict Minerals

by Cydney Posner There may be something of an internal battle among the commissioners on what to do about the conflict minerals decision of the D.C. Circuit. You’ll recall that the district court had upheld the rule in its entirety, and that the D.C. Circuit upheld most aspects of the […]

Revised Statement on WKSI Waivers

by Cydney Posner The SEC has today posted a Revised Statement on WKSI Waivers, so if you’re in the market for a waiver, be sure to consult the most recent version.

SEC tells us how to tweet a legend

by Cydney Posner The SEC has posted some new CDIs that relate to the use of required legends in connection with communications on Twitter or other electronic platforms that limit the number of characters used – if there aren’t any now, I’m sure there will be. The CDIs also address […]

Environmental Risk Disclosure

By Cydney Posner This article from The Economist, discusses the prevalence of increased disclosure about environmental  impact and vulnerability to green regulation.  In some cases, the  enhanced disclosure is designed to head off shareholder proposals.  Until recently, there was not much discussion of environmental exposure; however, according “to CDP, a group […]

SEC’s Conflict Minerals Rules Struck Down in Part on First Amendment Grounds

  By Cydney Posner In October of 2012, the National Association of Manufacturers, U.S. Chamber of Commerce and Business Roundtable filed a lawsuit asking the court to modify or set aside the SEC’s conflict minerals rules, which implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. […]