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

Repricing Underwater Options

Public companies in a number of sectors have recently experienced a significant decline in their share price. In addition, the conflict in Ukraine and macro-economic factors continue to impact the economy. Nevertheless, the labor market remains tight and companies are struggling to retain talent. This goal can be undermined when stock options awarded during better […]

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Statement by Chair Gensler on Proposed Updates to Names Rule

Today [May 25, 2022], the Commission is considering a proposal to update the Names Rule. I am pleased to support this proposal because, if adopted, it would modernize this key rule for today’s markets and enhance the transparency of the asset management field. A fund’s name is often one of the most important pieces of […]

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Statement by Commissioner Peirce on Proposed Updates to Names Rule

Thank you, Mr. Chair, and thank you to the staff in the Divisions of Investment Management and Economic and Risk Analysis, and the Office of the General Counsel, and to others at the Commission who worked on this proposal. Thank you for meeting demanding deadlines under considerable pressure and for fielding my many questions with […]

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Weekly Roundup: May 20-26, 2022

SEC Files Fraud Complaint over False Safety Claims Posted by Jason Halper, Mark Beardsworth, and Duncan Grieve, Cadwalader, Wickersham & Taft LLP, on Friday, May 20, 2022 Tags: Brazil, Corporate crime, Disclosure, ESG, International corporate governance, Misconduct, SEC, SEC enforcement, Securities enforcement, Stakeholders A Tale of Two Networks: Common Ownership and Product Market Rivalry Posted by Florian Ederer (Yale) and Bruno Pellegrino (University of Maryland), on Friday, […]

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Statement by Chair Gensler on ESG Disclosures Proposal

Today [May 25, 2022], the Commission is considering a proposal to improve disclosures by certain investment advisers and funds that purport to take Environmental, Social, and Governance (ESG) factors into consideration when making investing decisions. I am pleased to support this proposal because, if adopted, it would establish disclosure requirements for funds and advisers that […]

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Statement by Commissioner Peirce on ESG Disclosures Proposal

Thank you, Mr. Chair. A key impetus for today’s rulemaking is a legitimate concern about the practice of greenwashing by investment advisers and investment companies. This concern is real because advisers can mint money by calling their products and services “green” without doing anything special to justify that label. Only days ago, we settled an […]

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Statement by Commissioner Lee on ESG Disclosures Proposal

I am pleased to support today’s proposal to bring greater transparency and accountability to sustainable investing. There has been explosive growth in investor interest and demand around such investments, both domestically and internationally. With that increasing demand comes increasing need for consistent, comparable, and reliable information—information to help protect investors from “greenwashing,” or exaggerated or […]

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Nosedive: Boeing and the Corruption of the Deferred Prosecution Agreement

For public corporations, the deferred prosecution agreement (or “DPA”) has become the default rule. Whatever the crisis or scandal—foreign corrupt practices, securities fraud, opioids—the response of the public corporation is to cut a deal with the U.S. Attorney under which it conducts an internal investigation, agrees to a joint “Statement of Facts” describing the misconduct, […]

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The Cost of Proxy Contests

By now we’ve heard a lot about the universal proxy card (UPC), and how it makes life easier for activist investors and harder for companies. We set forth the highlights earlier. Many observers note UPC will lower the cost of proxy contests, and thus encourage more of them. Here, we dig into exactly how that […]

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Hell or High Water Provisions in Merger Agreements: A Practical Approach

When a business is being sold, the sellers, regardless of whether it is the Board of Directors of a public company, or a private owner, take into consideration three overarching factors: price, speed, and certainty. In recent years, particularly in light of the Biden Administration’s focus on antitrust enforcement and policy, antitrust clearance under the […]

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