Publish the list — hold the irony
by Cydney Posner As required by section 1502(d)(3)(C) of Dodd-Frank, the U.S. Commerce Department has compiled and posted (albeit more than a year late) a list of ”all known conflict mineral processing facilities worldwide.” Without the slightest hint of irony, Commerce notes that the list does “not indicate whether a […]
Is it OK to delay implementation of the new COSO framework?
by Cydney Posner With the original 1992 COSO internal control framework deemed by COSO to be “superseded” as of December 15, 2014, companies are fast approaching the deadline for adoption of the updated 2013 COSO framework, But is it really a deadline? As quoted in this article in Compliance Week, COSO […]
Stinging dissent by Commissioner Aguilar: Is the SEC making fraudulent behavior look like an innocent mistake?
by Cydney Posner Following on the heels of a case, discussed in this post, in which a CEO and CFO were charged with internal control and books and records violations (but no typical financial statement fraud allegation), comes another case against a CEO and CFO that likewise concluded with violations of […]
SEC issues fee rate advisory for fiscal 2015
by Cydney Posner On Friday, the SEC announced that the fees for registration of securities and certain other transactions in fiscal 2015 will be $116.20 per million dollars, down from $128.80 per million dollars last year. Under Dodd-Frank, the annual rate changes must take effect on the first day of […]
Does size matter?
by Cydney Posner According to a study of boards of directors conducted for the WSJ, size does matter, and major corporations with smaller boards of directors tend to outperform their peers with larger boards. (The study is discussed in the article entitled “Smaller Boards Get Bigger Returns” by Joann S. […]
FASB issues new ASU to fill the gap in GAAP guidance regarding going-concern uncertainties
by Cydney Posner Yesterday, FASB issued an Accounting Standards Update (ASU) regarding the disclosure of uncertainties about a company’s ability to continue as a going concern. ASU 2014-15 “provides guidance to an organization’s management, with principles and definitions that are intended to reduce diversity in the timing and content of disclosures […]
SEC approves NASDAQ proposal to eliminate automatic upgrade to Global Select Market
by Cydney Posner The SEC has approved NASDAQ’s proposal, as discussed in this post, to modify Rule 5305 to eliminate the annual review and automatic transfer of companies from the NASDAQ Global Market to the NASDAQ Global Select Market. As a result, NASDAQ will now review Global Market-listed companies for […]
SEC staff to issue guidance related to new revenue recognition standard
by Cydney Posner With 700 pages of new rules released regarding FASB’s new revenue recognition standard, it’s no wonder that companies have a lot of questions about the rules. (For more on the standard, see this post .) According to this article in Compliance Week, the SEC is on the verge […]
Fee-shifting bylaw developments in the courts
by Cydney Posner Those expecting that the Delaware court, in a case involving Hemispherx, would soon address the as-applied validity of a fee-shifting bylaw may be disappointed. (As discussed in this post and this Cooley Alert, the Delaware Supreme has already ruled in another case that a “fee-shifting” bylaw adopted […]
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