Tag: Compliance and Disclosure Interpretations
New CDIs regarding registration fees and Form S-8
by Cydney Posner More new CDIs from Corp Fin, some relating to Form S-8 and the computation of registration fees under Rule 457:
New CDI regarding “baby shelf” offerings on Form S-3
by Cydney Posner Corp Fin has issued a new CDI regarding Form S-3 and limited primary offerings under General Instruction I.B.6., that is, “baby shelf” offerings by issuers with public floats below $75 million. As you may recall, Instruction I.B.6 allows a company with a public float below $75 million […]
Mail seven copies of your glossy annual report to the SEC? Not anymore, so long as….
by Cydney Posner Corp Fin has just issued a welcome new CDI under the Proxy Rules and Schedule 14A. As you know, under Exchange Act Rule 14a-3(c) and Rule 14c-3(b), companies must mail to the SEC, “solely for its information,” seven copies of their glossy annual reports sent to shareholders. […]
Corp Fin issues new and revised CDIs on Rule 701 and Rule 144(d)
by Cydney Posner More new and revised CDIs from Corp Fin today. This time, the CDIs address Rule 701 and the Rule 144(d) holding period.
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:
You must be logged in to post a comment.