Author Archives: Harvard Law School Forum on Corporate Governance and Financial Regulation

Can a Public Company Effectively Opt Out of Rule 14a-8?

For almost eighty years Rule 14a-8 has been an integral part of the regulatory landscape, serving as a widely used means of communication between securityholders and the companies in which they invest. While the rule has been not been without controversy and has been tweaked from time to time, its fundamental objective, i.e., subject to […]

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Q4 2019 Equilar Gender Diversity Index

For the ninth consecutive quarter, the Equilar Gender Diversity Index (GDI) has increased. With the percentage of women on the boards of Russell 3000 companies increasing from 20.9% in Q3 2019 to 21.5% in Q4 2019, the GDI is now 0.43, where 1.0 represents parity among men and women. The continuous upward trend of women […]

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The “Market Exception” in Appraisal Statutes

Introduction: Public Shareholders and Appraisal Rights Appraisal is a right and a remedy. Available by statute in all states, appraisal provides dissenting shareholders the right to require the corporation to pay them the ‘fair value’ of their shares upon some mergers or other fundamental changes. Appraisal statutes provide procedures for dissenting shareholders to receive a […]

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Ten Considerations for Boards of Directors

The 2019 novel coronavirus (COVID-19) pandemic presents complex issues for corporations and their boards of directors to navigate. This briefing is intended to provide a high-level overview of the types of issues that boards of directors of both public and private companies may find relevant to focus on in the current environment. Corporate management bears […]

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M&A in Times of COVID-19

COVID-19 may cause buyers and sellers to reassess valuations, adjust pricing mechanisms and implement new methodologies for interim operations and crisis response management at a target. Transaction participants should take steps to mitigate the potential disruption to deal processes and timelines caused by the virus. Parties should think through risk allocation—including the MAC clause—and how […]

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Non-U.S. Issuers Targeted in Securities Class Action Lawsuits Filed in the United States

Introduction Companies headquartered or with principal places of business outside the United States (“non-U.S. issuers”) continue to be targets of securities class actions filed in the United States. Indeed, 2019 continued to see an uptick in the number of securities class action lawsuits brought against non-U.S. issuers from the previous year, consistent with the general […]

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Public Statement by Chairman Jay Clayton for FSOC Open Meeting

The women and men of the SEC are focused on two overriding issues: (1) we are facing a national challenge—an unprecedented health and safety crisis that requires all Americans, for the sake of all Americans, to significantly change our daily behavior, including behavior at our banks, broker-dealers, investment advisers and other market participants; and (2) […]

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Closing the Gender Pay Gap

From Wall Street to the soccer pitch, public interest in addressing the gender pay gap is greater than ever. While the press covers the U.S. Women’s World Cup team’s struggles to earn equal pay for equal (or, rather, superior) work, ESG-focused investors are demanding more granular disclosure of companies’ efforts to close the gender pay […]

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Regulation and Investor Expectations: The UK 2020 AGM Season

Executive Summary Ever since the financial crisis of 2008, the level of scrutiny on Boards of Directors and companies has grown, with the focus on corporate governance becoming particularly pronounced over the past five years. The 2018 iteration of the new UK Code included a number of substantive changes. The growing capabilities of institutional investors […]

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The Crisis and the Activists and Raiders

For the past two weeks a number of activists and takeover raiders have sought to take advantage of the COVID-19 crisis by launching attacks on companies they view as vulnerable. Unlike the bedrock American companies drained by the crisis, there is ample dry powder in the coffers of some funds and companies to support the […]

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