Tag: Compliance and Disclosure Interpretations

Corp Fin posts new CDIs on pay-ratio disclosure

by Cydney Posner Corp Fin has just issued several new CDIs regarding pay-ratio disclosure (S-K Item 402(u)). As you probably recall, the pay-ratio provision mandates that the SEC require most public companies to disclose, in a wide range of their SEC filings: the median of the annual total compensation of […]

New CDI regarding investments through a self-directed “brokerage window” under a 401(k)

by Cydney Posner Today, Corp Fin posted a new CDI under both Securities Act Section 5 and Form S-8.   The CDI involves the issue of whether a company-sponsored 401(k) plan that does not offer an employer securities fund as an investment alternative might still be deemed to be offering employer […]

Corp Fin issues revised CDI regarding disclosure about selling shareholder entities

by Cydney Posner Last week, Corp Fin revised a CDI regarding disclosure about selling shareholder entities and withdrew another CDI on the same topic.

Corp Fin issues new CDIs providing guidance on Rule 701 primarily in the merger context

by Cydney Posner Corp Fin has just issued some new CDIs providing guidance on Rule 701, with all but one of the CDIs addressing the application of Rule 701 in the context of merger transactions.  The new CDIs are summarized below: