Category: Securities

Nasdaq proposes “golden leash” disclosure, but will it prohibit the practice?

by Cydney Posner At the end of January, Nasdaq filed with the SEC a rule proposal related to third-party compensation of directors in connection with their candidacy for and/or service on company boards, often referred to as “golden leash” arrangements.  Golden leash arrangements are most common in connection with board nominations […]

Deadline for filing cert petition extended again in conflict minerals case

by Cydney Posner The Chief Justice has granted another extension of time for the SEC to file a petition for cert in Natl Assoc. of Manufacturers v. SEC, the conflict minerals case. The SEC now has until April 7, 2016 to file its petition.

SEC’s investor advocate echoes concerns of SEC’s Investor Advisory Committee on Nasdaq Solicitation of Comments

by Cydney Posner The SEC’s Investor Advocate has issued a letter to Nasdaq concerning Nasdaq’s Solicitation of Comments regarding certain Nasdaq shareholder approval rules.  The comments largely echo the comments of the SEC’s Investor Advisory Committee, which were fundamentally skeptical of  the Solicitation. (See this PubCo post.)

Director resignation policies under fire

by Cydney Posner The originator of the “Pfizer model” of “plurality plus” voting for directors — Pfizer —  will be facing a shareholder proposal  (January 29, from the Chevedden folks) calling for a change to Pfizer’s governing documents and policies regarding majority voting. The “plurality plus” model requires directors to […]

Corp Fin Staff grants no-action relief allowing exclusion of shareholder proposals for proxy access under Rule 14a-8(i)(10)

by Cydney Posner Now that Corp Fin has issued Staff Legal Bulletin 14H providing guidance that, for most practical purposes, eliminates the availability of Rule 14a-8(i)(9) (see this PubCo post) to exclude shareholder proposals that conflict with management proposals, there has been substantial speculation about the contours of Rule 14a-8(i)(10), the exclusion for proposals […]

Want to increase company performance? Increase the proportion of women in corporate leadership

by Cydney Posner So says a new study from the Peterson Institute for International Economics.  The results suggest that the presence of women in corporate leadership positions may improve firm performance and that “the magnitudes of the correlations are not small.”

SEC’s Investor Advisory Committee takes on Nasdaq

by Cydney Posner At the January meeting of the SEC’s Investor Advisory Committee, two Nasdaq representatives made a presentation regarding the recent Solicitation of Comments by the Nasdaq Listing and Hearing Review Council, a standing independent advisory committee, regarding some of the Nasdaq shareholder approval rules.  The reaction of the […]

Should insiders be permitted to pledge their company shares?

by Cydney Posner Many company policies prohibit (or severely limit) officers and directors from pledging their company shares against margin loans, and, as discussed in an article in last week’s WSJ, there seems to be good reason for that practice. 

SEC’s Investor Advisory Committee takes on FASB

by Cydney Posner At Thursday’s meeting of the SEC’s Investor Advisory Committee, the Committee approved the submission of a comment letter urging FASB to reconsider its proposal to make changes to the concept of “materiality” embodied in FASB’s Conceptual Framework for Financial Reporting and FASB’s guidance on Notes to Financial […]

SEC adopts rules to implement two provisions of the FAST Act

by Cydney Posner The SEC has approved interim final rules  implementing two provisions of the Fixing America’s Surface Transportation (FAST) Act.  As you may recall, the FAST Act was signed into law in early December and contained several measures that modified the JOBS Act or otherwise related to capital raising for […]