Caitlyn Campbell, John Nowak, and Paul Helms are Partners at McDermott Will & Schulte. This post is based on a McDermott memorandum by Ms. Campbell, Mr. Nowak, and Mr. Helms, and Gabriel Gross.
Overview
On June 4, 2026, the Supreme Court in Sripetch v. SEC unanimously held that the US Securities and Exchange Commission (SEC) need not prove that investors suffered a pecuniary loss before obtaining disgorgement. In doing so, the Court resolved a circuit split between the US Court of Appeals for the First Circuit and the Court of Appeals for the Ninth Circuit (both of which permitted disgorgement absent proof of investor losses) and the Second Circuit (which required such a showing). The Supreme Court’s decision, however, was notably narrow and left unresolved several significant questions concerning the scope and constitutional status of the SEC’s disgorgement authority, creating investigation and litigation opportunities for defendants.
This year marks the 50th anniversary of the OECD’s Guidelines For Multinational Corporations For Responsible Business Conduct, a set of principles to which the United States, the other OECD nations, and additional signatories totaling 52 nations comprising nearly two-thirds of the world’s economic activity and the bulk of market-based, democratic nations, adhere. In this condensed set of remarks, the longer version of which can be found 
Comment Letter on the SEC’s Proposal to Replace Quarterly Reporting with Semiannual Reporting
More from: Carine Smith Ihenacho, Snorre Gjerde, Norges Bank
Carine Smith Ihenacho is the Chief Governance and Compliance Officer and Snorre Gjerde is the Lead Investment Stewardship Manager at Norges Bank Investment Management. This post is based on their SEC comment letter.
We refer to the Securities and Exchange Commission (SEC)’s request for comment on the proposed amendments to allow companies to file semiannual reports on new Form 10-S in lieu of quarterly reports on Form 10-Q to meet their interim reporting obligations under the Securities Exchange Act of 1934. We appreciate the opportunity to contribute our perspective.
Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank that manages the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As of year-end 2025, we managed over 2 trillion USD in assets, with the United States representing our largest market at 53% of total investments. Within our equity portfolio, 822 billion USD was invested in shares of 1,306 U.S. public companies. We are a minority shareholder in U.S. public companies, with an average equity ownership of 1.18 percent.
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