Monthly Archives: June 2026

Supreme Court: SEC May Seek Disgorgement of Profits Without Proving Investor Loss

Nekia Hackworth, Sarah Levine, and David Peavler are Partners at Jones Day. This post is based on a Jones Day memorandum by Ms. Hackworth, Ms. Levine, Mr. Peavler, Laura Pruitt, and Evan Singer.

The Supreme Court’s unanimous decision resolves a significant question regarding the SEC’s disgorgement authority, foreclosing defendants from contesting disgorgement awards based on the absence of investor financial harm.

On June 4, 2026, the Supreme Court unanimously held in Sripetch v. Securities and Exchange Commission that the SEC need not prove that investors suffered pecuniary loss before obtaining disgorgement through an enforcement action in federal court.

READ MORE »

Stay Grounded on Moonshot IPOs

Rodney Comegys is Chief Investment Officer, Vanguard Capital Management, and Head of Global Equity at Vanguard. This post is based on a Vanguard publication.

The impending SpaceX initial public offering (IPO) has some investors looking for a liftoff in their index funds and ETFs—even as others brace for potential volatility.

While Vanguard’s index products will purchase shares in SpaceX in the days and weeks following the IPO launch, we will take a more grounded approach. Investors should understand that index rules, which govern the Vanguard products that seek to track them, will require a measured incorporation of stock from any new public company.

Investors should be reminded that in addition to diversification, low costs, and transparency, one of indexing’s core principles is to let markets, not hype, settle the outcomes.

READ MORE »

Weekly Roundup: June 12-18, 2026


More from:

This roundup contains a collection of the posts published on the Forum during the week of June 12-18, 2026


The 2026 Proxy Season in Progress



We’re Not Rolling the Dice in Nevada



Considerations for Shareholder Proposals in a Post-Rule 14a-8 World


Form PF Amendments Signal Slimmer Private Fund Reporting


When Stock Prices Become Targets: Earnings Management and Price Informativeness in China



Chancery Finds Funds Liable for Aiding Directors’ Fiduciary Breaches


Global CEO Turnover Index: Key Trends to the End of Q1 2026


Tariff Disclosures and Executive Compensation



2026 U.S. Proxy Season: Evolving Incentive Design and CEO Pay Trends

Subodh Mishra is the Global Head of Communications at ISS STOXX. This post is based on an ISS-Corporate memorandum by Craig Benedict, Associate Vice President for Compensation and Governance Advisory; and Chris Sayo, Senior Associate for Data Analytics, at ISS-Corporate.

As 2026 U.S. proxy filings reach critical mass, clear trends in CEO compensation have emerged. Consistent with recent years, CEO pay has progressed at a steady upward clip, and incentive design practices continue to evolve. As shareholders cast their say-on-pay votes this proxy season, pay-for-performance alignment, incentive structure rigor, and incentive time horizon are emerging as areas of elevated investor scrutiny.

CEO Pay Climbs to Record Highs

CEO pay has increased steadily in fiscal year 2025, reaching a new record for both the S&P 500 and the Russell 3000. Historically, the Russell 3000 has been categorized by starts and stops, while the S&P 500 has increased steadily over the last 10 years. This year, both indices have seen modest increases that look more like a continuing long-term trend than a divergence from years past.

READ MORE »

Tariff Disclosures and Executive Compensation

Eleanor Viney is an Analyst, Neil McCarthy is Co-Founder and Chief Product Officer, and Emily Drazan Chapman is a Legal AI Architect at DragonGC. This post is based on their DragonGC memorandum.

Executive Summary

This report analyzes the impact of recent tariffs on executive compensation plans across 2026 proxy statement filings from S&P 500 companies. Drawing on the 406 proxy (DEF 14A) statements filed from January 1, 2026 to May 1, 2026—representing 81.2% of the S&P 500 index—the report documents how compensation committees characterized, measured, and responded to the tariff environment in designing and evaluating executive pay outcomes for the 2025 fiscal year.

Of the 406 filings covering the 2025 fiscal year, 136 (33.5%) contained at least one reference to tariffs, with tariff-related disclosures highly concentrated among companies in the industrial, manufacturing, and consumer goods sectors. Within that set, 62 companies (15.3% of all filers; 45.6% of those mentioning tariffs) explicitly linked tariff developments to executive pay plan design, goal setting, performance measurement, or payout decisions. The remaining 74 filings (54.4%) referenced tariffs generally (often in forward-looking statements or risk disclosure language) without connecting the discussion to compensation outcomes.

READ MORE »

Global CEO Turnover Index: Key Trends to the End of Q1 2026

Rusty O’Kelley is a Managing Director, Laura Sanderson is a Senior Member of the Board and CEO Advisory, and Emma Combe leads the UK Board Practice at Russell Reynolds Associates. This post is based on their Russell Reynolds memorandum.

1. Boards showed a stronger preference for experienced CEOs—especially in the S&P 500

The most notable shift in Q1 2026 was the increase in experienced CEO hires. Globally, 26% of incoming CEOs had prior experience of serving as a CEO of a publicly listed company, up from 17% in Q1 2025 and 8% in Q1 2024.

This trend was particularly pronounced in the S&P 500, where 41% of incoming CEOs were experienced CEOs—the highest Q1 level in our nine-year tracking period—up from 25% in Q1 2025 and 9% in Q1 2024. In absolute terms, this equates to nine appointments, compared with five in Q1 2025 and two in Q1 2024.

READ MORE »

Chancery Finds Funds Liable for Aiding Directors’ Fiduciary Breaches

Gail Weinstein is a Senior Counsel, Philip Richter is a Partner, and Steven Epstein is the Managing Partner at Fried, Frank, Harris, Shriver & Jacobson LLP. This post is based on a Fried Frank memorandum by Ms. Weinstein, Mr. Richter, Mr. Epstein, Steven SteinmanMaxwell Yim, and Hannah Reiner; and is part of the Delaware law series; links to other posts in the series are available here.

In Guilbeau v. Footprint (May 11, 2026), the Court of Chancery held, at the pleading stage of litigation, that it was reasonable to infer that certain directors of Footprint International Holdco, Inc., a non-controlled Delaware corporation (the “Company”), breached their fiduciary duties when they approved a Company financing (the “Financing”) that was proposed, and largely funded, by three institutional investors (the “Funds”) that were among the Company’s largest stockholders. The court also held that the Funds may have aided and abetted the directors’ breaches, acting through their designees on the Company’s board.

The Financing raised $500 million ($450 million of it from the Funds) through the issuance of a new class of preferred stock (the “Class F Stock”), at a time the Company was verging on insolvency. The Financing was recommended by a three-member special committee of independent directors (the “Committee”) and approved by the full ten-person board of directors (the “Board”) (which included one designee from each of the three Funds—collectively, the “Fund Designees). As would be typical in connection with this type of financing, the Company provided special benefits to the Funds and to two large stockholders (“ZenCap” and “Koch”) who had blocking rights.

READ MORE »

ISS Calls It Dilution. It Isn’t

Jessica Pollock is a Senior Research Associate at FCLTGlobal. This post is based on her FCLTGlobal memorandum.

Using equity as part of employee compensation reinforces an ownership culture across the employee base. And ownership by employees, executives, and board members has been shown to create value over the long term. Having “skin in the game” is largely considered a good idea. Yet, companies often receive pushback from proxy advisors such as ISS that issuing shares to provide equity to their team causes dilution, even if the companies repurchase an equal number of shares in the marketplace.

How can there be dilution when the number of shares issued and the number repurchased line up?

ISS’s dilution formula produces a figure closer to gross share issuance than net dilution. For companies with active buyback programs and broad-based equity plans, the gap between the two can be significant enough to drive an Against recommendation that doesn’t reflect economic reality.

READ MORE »

When Stock Prices Become Targets: Earnings Management and Price Informativeness in China

Zhiguo He is the James Irvin Miller Professor of Finance at Stanford University; Wenxi Jiang is a Professor of Finance at the Chinese University of Hong Kong Business School; and Wei Xiong is the John H. Scully ’66 Professor in Finance and Professor of Economics at Princeton University. This post is based on their recent paper.

China’s stock market appears to predict future corporate earnings, but this predictability does not necessarily mean prices are a clean “crystal ball” for fundamentals. High valuations also appear to pressure firms to cater to investor expectations by inflating reported earnings, especially through non-recurring gains and losses. The result is a distinctive pattern: short-run earnings predictability followed by longer-run reversal, suggesting that price informativeness and earnings management can reinforce each other.

Can stock markets discipline firms and allocate capital efficiently when the accounting system is still developing? This question is central to current debates about China’s capital markets. Policymakers have sought to make the A-share market a more important venue for financing innovation, disciplining listed firms, and giving households a larger stake in corporate growth. At the same time, China’s equity market remains known for speculative trading, retail investor dominance, weak delisting discipline in earlier years, and recurring concerns about the quality of listed firms’ financial reports.

READ MORE »

Form PF Amendments Signal Slimmer Private Fund Reporting

Marc Ponchione and Sheena Paul are Partners and Juliet Han is a Counsel at Debevoise & Plimpton LLP. This post is based on a Debevoise memorandum by Mr. Ponchione, Ms. Paul, Ms. Han, Kristin Snyder, Jonathan Adler, and Ali Nierenberg.

Background

On April 20, 2026, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC,” and together with the SEC, the “Commissions”) jointly proposed amendments to Form PF (the “Proposed Amendments”) that, if adopted, would significantly reduce reporting burdens for many private fund advisers. The Proposed Amendments appear designed to realign Form PF more closely with one of its core purposes: providing information for the Financial Stability Oversight Council’s assessment of systemic risk. The relief is a welcome change for investment advisers, and the SEC’s request for comment on a diversity of issues signals its willingness to engage with industry and stakeholders on practical solutions in a new era of a slightly slimmed down Form PF.

READ MORE »

Page 3 of 7
1 2 3 4 5 6 7