The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Sat, 16 May 2026 11:30:10 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png SEC’s Recent Public Company Settlement Provides Guidance for Corporate Resolutions Under the Current Administration – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 SEC’s Recent Public Company Settlement Provides Guidance for Corporate Resolutions Under the Current Administration https://corpgov.law.harvard.edu/2026/05/16/secs-recent-public-company-settlement-provides-guidance-for-corporate-resolutions-under-the-current-administration/?utm_source=rss&utm_medium=rss&utm_campaign=secs-recent-public-company-settlement-provides-guidance-for-corporate-resolutions-under-the-current-administration https://corpgov.law.harvard.edu/2026/05/16/secs-recent-public-company-settlement-provides-guidance-for-corporate-resolutions-under-the-current-administration/#respond Sat, 16 May 2026 11:30:10 +0000 https://corpgov.law.harvard.edu/?p=180947?d=20260515163529EDT Posted by Anita Bandy, Andrew Lawrence, and Mayra Suárez, Skadden, Arps, Slate, Meagher & Flom LLP, on Saturday, May 16, 2026
Editor's Note:

Anita Bandy and Andrew Lawrence are Partners and Mayra Suárez is Counsel at Skadden, Arps, Slate, Meagher & Flom LLP. This post is based on a Skadden memorandum by Ms. Bandy, Mr. Lawrence, Ms. Suárez, and Hannah Henderson.

Executive Summary

  • What’s new: The SEC filed a settled enforcement action against a company and two executives in connection with books-and-records and internal accounting controls failures, notably imposing no corporate penalty despite a lack of self-reporting.
  • Why it matters: The settlement underscores that while the SEC is stepping away from untested theories for charging internal controls violations, the agency is continuing to pursue “back-to-basics” financial reporting issues against companies and their executives, even when the conduct does not result in material errors.
  • What to do next: Companies will want to consider if they have robust accounting controls and policies that are consistently followed, and when internal controls uncover a potential issue, company management and audit committees should review and remediate promptly.

(more…)

]]> https://corpgov.law.harvard.edu/2026/05/16/secs-recent-public-company-settlement-provides-guidance-for-corporate-resolutions-under-the-current-administration/feed/ 0