Monthly Archives: February 2026

Private Equity for All: The Paradoxical Push to Democratize Private Markets

William Clayton is a Professor of Law at J. Reuben Clark Law School, Brigham Young University, and Elisabeth de Fontenay is the Karl W. Leo Professor of Law at Duke University School of Law. This post is based on their recent paper, forthcoming in the Duke Law Journal.

Efforts to open private equity and other private assets to retail investors—including now through 401(k) plans—are often framed as a long-overdue democratization of superior investment opportunities. Indeed, private equity has always been viewed as special, both for its market-beating returns and its success in making companies more profitable, yet it has historically been off-limits to retail investors.

In Private Equity for All: The Paradoxical Push to Democratize Private Markets, we argue that the push to democratize private equity is subject to a glaring paradox. Far from sharing the spoils of private equity with the public, opening private markets to retail investors at scale is likely to erode or eliminate each and every one of the supposed advantages of private equity over public markets—not just for retail investors but across the market. Consequently, whether private equity’s appeal lies in superior investor returns or superior corporate governance, broad retail access is likely to ensure that neither one is achieved.

The debate has become urgent. New products targeting retail investors are continually being launched by private-asset managers and blessed by regulators. And in the summer of 2025, an executive order directed the U.S. Securities and Exchange Commission and U.S. Department of Labor to pave the way for private equity to access a particularly massive pool of retail capital: the $10 trillion 401(k) market. READ MORE »

Vanguard Capital Management: Proxy Voting Policy for U.S. Portfolio Companies

Glenn Booraem is the Head of Investment Stewardship, Vanguard Capital Management at Vanguard. This post is based on a Vanguard piece.

Introduction

This proxy voting policy (the Policy) describes general positions on matters that may be subject to a shareholder vote at U.S.-domiciled companies and is aligned with governance practices believed to support long-term shareholder returns. The Policy has been adopted by the boards (or relevant governing bodies) of funds and portfolios managed by certain Vanguard-affiliated entities including U.S.-domiciled mutual funds and ETFs advised by Vanguard Capital Management, LLC (VCM), as well as the boards of Vanguard Asset Management, Ltd., Vanguard Fiduciary Trust Company, Vanguard Global Advisers, LLC, and Vanguard Investments Australia Ltd in connection with their management of certain equity index funds and portfolios (together with the U.S.-domiciled mutual funds and ETFs advised by VCM, the “Funds”). The adoption of this Policy is anchored in the belief that effective corporate governance practices support long-term investment returns.

It is important to note that proposals—whether submitted by company management or other shareholders—often require a facts-and-circumstances analysis based on an expansive set of factors. While the Policy may recommend a particular voting decision, all proposals are voted case by case as determined in the best interests of each Fund consistent with its investment objective. The Policy is applied over an extended period of time; as such, if a company’s board is not responsive to voting results on certain matters, support may be withheld for those and other matters in the future.

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Weekly Roundup: February 20-26, 2026


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This roundup contains a collection of the posts published on the Forum during the week of February 20-26, 2026

Delaware Supreme Court Affirms D&O Coverage


Succession Planning in Private Equity: A Strategic Imperative for GPs and LPs


Artificial Intelligence in the Boardroom


Recent Developments for Directors




2026 Outlook for Corporate Citizenship and Philanthropy


SEC Adds Flexibility to M&A, Proxy, and Tender Offer Rules with New Interpretations


Remarks by Chair Atkins on Capital Formation and the INVEST Act



Nevada v. Delaware: The New Market for Corporate Law


Remarks by Commissioner Peirce on Private Secondaries in Capital Markets


Remarks by Commissioner Peirce on Private Secondaries in Capital Markets

Hester M. Peirce is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent remarks. The views expressed in this post are those of Commissioner Peirce and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Good morning, and thank you all for attending today’s meeting. Welcome to the Committee’s new members. I appreciate the work of the Committee and the willingness of experts to share their views as panelists. I also appreciate the work of the Office of the Advocate for Small Business Capital Formation in supporting the Committee’s work.

I commend the Committee for its continued focus on finders and look forward to any recommendations the Committee develops. As I mentioned at the last meeting, current activity in this area is shaped by a muddled web of no-action letters that is out of step with practical realities. Last meeting’s discussion of status quo finder activity underscored that point. The absence of a finder’s framework does not deter bad actors. Good actors may unwittingly act as finders, or, if they are aware of the law’s unduly strict limitations, may observe from the sidelines rather than helping to match investors and companies. I appreciated your in-depth discussion of what sensible finders regulation could look like and your focus on how finders can help companies to raise money in amounts too small for brokers to bother with. You covered a lot of other territory as well, from essential disclosures for finder activity to AI agents. I hope today’s discussion will be equally interesting and constructive as you devise recommendations.

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Nevada v. Delaware: The New Market for Corporate Law

Michal Barzuza is a Professor of Law at the University of Virginia. This post is based on her recent paper.

The Article provides the first comprehensive analysis of Nevada’s statutory amendments, legislative history, and case law. It shows that Nevada corporate law effectively forecloses shareholder litigation eliminating the shareholder rights and management accountability that have long characterized American corporate law. It reveals how plaintiff shareholders face an impossible bind: they must plead intentional wrongdoing to survive dismissal, yet Nevada uniquely bars access to the books and records necessary to meet this burden.

Nevada corporate law has become a central focus in corporate America. Nevada has emerged as Delaware’s principal competitor, second only to Delaware in attracting out-of-state incorporations while dominating reincorporations out of Delaware. Firms cite reduced litigation exposure as a key advantage of incorporating in Nevada. The competitive pressure from Nevada is evident: Delaware amended its law to reduce scrutiny of self-dealing transactions, moving closer to Nevada’s approach, and Texas has incorporated elements of Nevada’s statutory scheme.[1] READ MORE »

Vanguard Portfolio Management: Proxy Voting Policy for U.S. Portfolio Companies

Carolyn Cross is the Head of Investment Stewardship, Vanguard Portfolio Management at Vanguard, Inc. This post is based on a Vanguard piece.

Introduction

This proxy voting policy (the Policy) describes general positions on proxy proposals that may be subject to a shareholder vote at U.S.-domiciled companies and is aligned with governance practices believed to support long-term shareholder returns. The Policy has been adopted by the boards (or relevant governing bodies) of funds and portfolios managed by certain Vanguard-affiliated entities including U.S.-domiciled mutual funds and ETFs advised by Vanguard Portfolio Management, LLC (VPM), as well as the boards of Vanguard Fiduciary Trust Company and Vanguard Global Advisers, LLC in connection with their management of certain equity index and quantitative equity funds and portfolios (together with the U.S.-domiciled mutual funds and ETFs advised by VPM, the “Funds”). The adoption of this Policy is anchored in the belief that effective corporate governance practices support long-term investment returns.

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Remarks by Chair Atkins on Capital Formation and the INVEST Act

Paul S. Atkins is the Chairman of the U.S. Securities and Exchange Commission. This post is based on his recent remarks. The views expressed in the post are those of Chairman Atkins and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Good afternoon, ladies and gentlemen.[1] Let me begin by thanking our hosts at the U.S. Chamber for the invitation to join today’s program—and of course, for their advocacy on behalf of American enterprise.

I am also pleased to recognize a few leaders whose efforts brought us to this occasion: Chairmen Tim Scott and French Hill, as well as Chairwoman Ann Wagner. Their work reflects the conviction that American ingenuity flourishes when capital can move more freely to meet it. After all, capital formation is the instrument through which one can elevate a good idea into a business; a business into an employer; and an employer into a source of social mobility. Capital formation, in short, is how America prospers. And by any objective measure, our markets have prospered without peer.

Indeed, the United States leads the world in both market capitalization and trading volume. Our equity markets are four-and-a-half times larger than those of the next jurisdiction. But prosperity is not self-sustaining. Each generation must earn it anew by strengthening the structures that make our markets the world standard.

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SEC Adds Flexibility to M&A, Proxy, and Tender Offer Rules with New Interpretations

Ethan Klingsberg, Michael Levitt, and Elizabeth Bieber are Partners at Freshfields Bruckhaus Deringer LLP. This post is based on a Freshfields memorandum by Mr. Klingsberg, Mr. Levitt, Ms. Bieber, and Jeremy Barr.

On January 23, 2026, the Securities and Exchange Commission’s Division of Corporation Finance (“CorpFin”) published new and revised Compliance and Disclosure Interpretations (“C&DIs”) relating to the SEC’s M&A, proxy and tender offer rules.  The SEC staff thus continued a pattern from 2025 of introducing more flexibility for public companies and their management without the Commission’s undertaking notice-and-comment rulemaking. As noted below, these interpretative changes mesh with 2026 policy shifts by the Commission, SEC Chairman Paul Atkins, and staff to alter the balance in the relationship between management and shareholders.

And the staff may be far from finished.  On a panel at the annual January Northwestern Securities Regulation Institute in January 2026, CorpFin Associate Director for Specialized Disclosure Ted Yu welcomed public company feedback on where additional interpretative flexibility or formal rule changes regarding tender offers might be beneficial.

The following summarize the nature and implications of the higher profile January 2026 CorpFin C&DIs:

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2026 Outlook for Corporate Citizenship and Philanthropy

Matteo Tonello is the Head of Benchmarking and Analytics at The Conference Board, Inc. This post is based on a report developed by The Conference Board and co-authored by Andrew Jones, Principal Researcher, US Governance & Sustainability Center at The Conference Board.

Drawing on a recent survey of 70 corporate citizenship leaders, this report examines how companies are adjusting citizenship and philanthropy budgets, priorities, partnerships, and capabilities amid an evolving economic, policy, and reputational landscape.

Trusted Insights for What’s Ahead

  • Corporate citizenship budgets enter 2026 largely stable, although 52% of leaders said they expect to allocate more resources toward volunteering, while a significant minority anticipate reductions in cash grantmaking and sponsorships.
  • Many companies are preparing for greater discipline around allocation and timing of citizenship grants and expenditures, as the new US 1% charitable deduction floor reinforces tighter portfolio management and more deliberate pacing of cash grants.
  • Thematic priorities are narrowing toward broadly shared, economically grounded needs— notably food security, affordability, housing, and digital inclusion—while issues carrying higher political or reputational exposure show the steepest pullbacks.
  • Nonprofit fragility is emerging as a material execution risk: only 15% of leaders described partners as very or somewhat stable, with most attributing fragility to federal funding cuts.
  • Delivering impact in 2026 is constrained by both internal and external pressures, as sustained expectations to demonstrate business value coincide with uncertainty around nonprofit capacity, political polarization, and media scrutiny.
  • AI adoption within citizenship teams remains early stage and exploratory (55% of respondents), with key priorities for 2026 focused on staff literacy, reporting and analysis automation, and building foundational readiness before extending AI into higher-impact or outward-facing applications.

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Delaware Supreme Court Reverses Invalidation Of Stockholder Agreement, Finding Belated Facial Challenge Was Barred by Laches

Mallory Tosch Hoggatt, Jeff Hoschander, and Alan Goudiss are Partners at A&O Shearman. This post is based on their A&O Shearman memorandum and is part of the Delaware law series; links to other posts in the series are available here.

On January 20, 2026, in an opinion authored by Justice Gary F. Traynor, the Delaware Supreme Court reversed a decision by the Delaware Court of Chancery that had invalidated certain provisions in a stockholder agreement between a financial institution (the “Company”) and its founder and controlling stockholder.  Moelis & Co. v. West Palm Beach Firefighters Pension Fund, No. 340, 2024 (Del. Jan. 20, 2026).  The Court held that plaintiff’s facial challenge to the validity of the stockholder agreement was barred by the equitable doctrine of laches because plaintiff filed the lawsuit nine years after the parties entered into the agreement.

As discussed in our prior post, Vice Chancellor J. Travis Laster had issued a decision invalidating a number of provisions of the stockholder agreement, including a series of rights afforded to the controlling stockholder, finding that the stockholder agreement impermissibly delegated to the controller authority over governance activities that, under the Delaware General Corporation Law (“DGCL”), were exclusively reserved for the board.  In so holding, the Court of Chancery concluded that the challenged provisions violated DGCL Section 141(a) and were therefore void.  In a separate opinion, the Court of Chancery had also rejected defendants’ assertions that plaintiff’s challenge was time-barred, holding that equitable defenses are not available to defeat claims of statutory invalidity, and, in the alternative, that because plaintiff challenged an ongoing statutory violation, plaintiff’s claim continued to accrue so long as the agreement was in effect.  See W. Palm Beach Firefighters Pension Fund v. Moelis & Co., 2024 WL 550750 (Del. Ch. Feb. 12, 2024).

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