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

Statement by Chair Gensler on Registration of Security-Based Swap Execution Facilities

Today [April 6, 2022], the Commission is considering a proposal to create a framework for the registration of security-based swap execution facilities (security-based SEFs). I am pleased to support this proposal because, if adopted, it would increase the transparency and integrity of the traditionally opaque over-the-counter security-based swap market, fulfilling a mandate under the Dodd-Frank […]

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Posted in Derivatives, Practitioner Publications, Regulators Materials, Securities Regulation, Speeches & Testimony | Tagged , , , , , , , , | Comments Off on Statement by Chair Gensler on Registration of Security-Based Swap Execution Facilities

The Limits of SPAC Sponsor Earnouts

Introduction SPACs have been widely criticized for their misalignment of sponsor and shareholder interests and for the dilution inherent in their structure. A major source of these problems is the sponsor’s “promote,” under which sponsors receive 20% of post-IPO shares essentially for free. Earnouts, which cancel promote shares if post-merger price targets are not met, […]

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Corporate Leadership’s Indispensable Role in Promoting Equality

Last Friday, the 2020 California board diversity statute requiring publicly held domestic or foreign corporations whose principal executive office is located in California to have a minimum of “one director from an underrepresented community” on its board by December 31, 2021 was struck down by a Los Angeles County Superior Court judge as violating the Equal Protection Clause of the […]

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Posted in Boards of Directors, ESG, HLS Research, Practitioner Publications | Tagged , , , , , , , , , | 1 Comment

Statement by Commissioner Peirce on In the Matter of Lloyd D. Reed

The Commission’s Order finds that Lloyd D. Reed violated Exchange Act Section 10(b) and its accompanying Rule 10b-5 “by trading on material, non-public information [of Torotel, Inc.] in breach of his duty of trust and confidence owed to his business partner (“Business Partner”), who was also a Torotel director and family member.” In other words, […]

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Posted in Practitioner Publications, Regulators Materials, Securities Litigation & Enforcement, Securities Regulation, Speeches & Testimony | Tagged , , , , , , , , | Comments Off on Statement by Commissioner Peirce on In the Matter of Lloyd D. Reed

The SEC’s Proposed Climate-Related Disclosure Rules: Thoughts for Audit Committees

The SEC’s proposed amendments to Regulations S‑K and S‑X to require new climate-related disclosures will, if adopted, require an expansion in the scope and responsibilities of audit committees. As described in our prior memo, the rules contemplate domestic and foreign issuers disclosing, in registration statements, annual reports and audited financial statements, information on board and […]

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SEC Proposes Short Sale Disclosure Rules

On February 25, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it unanimously voted to approve proposed changes requiring certain institutional investment managers (managers) to report short sale-related information to the SEC. Proposed Rule 13f-2 under the Securities Exchange Act of 1934 (Exchange Act) would require managers exercising investment discretion over short positions […]

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Posted in Accounting & Disclosure, Institutional Investors, Practitioner Publications, Securities Regulation | Tagged , , , , , , | 1 Comment

Post-Doctoral Corporate Governance Fellowships For Finance, Economics, and Accounting Researchers

The Program on Corporate Governance at Harvard Law School (HLS) is seeking applications for Corporate Governance Fellowships from highly qualified candidates with graduate training in finance, economics, or accounting. Applications are considered on a rolling basis, and the start date is flexible. Appointments are for one year but the appointment period can be extended for […]

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Five Questions Boards Should Ask About the War in Ukraine

While still recovering from the disruptions of the global pandemic, many companies find themselves grappling with a new and, for the most part, unanticipated emergency. Russia’s invasion of Ukraine requires business leaders to remain in crisis-management mode. Many commentators suggest that what we are witnessing is only the beginning of a new, precarious period of […]

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SEC Proposes Rules Enhancing Cybersecurity Disclosures

On March 9, 2022, the Securities and Exchange Commission (SEC) proposed rules intended to enhance and standardize public company disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting. The proposed rules accomplish these objectives through specific, mandated disclosure requirements applicable to all companies in a manner designed to enhance comparability across issuers and industries. […]

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EU Taxonomy and the Future of Reporting

While the period up to 2018 was marked by an absence of ESG and sustainability focused regulatory pressure, in the period since, there have been efforts across the globe to ensure investors, financiers and companies pursue more sustainable business practices. At the forefront of those efforts has been the EU, which is seeking to become […]

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