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

Not All TSR Incentive Plans are Created Equal

Over the past few years, relative total shareholder return (TSR) has continued to be the most widely used executive long-term incentive (LTI) plan metric, even though its usage is leveling off to some degree at the CEO level as other incentive plan metrics become more popular. That said, due to its clear connection to shareholder […]

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Post Vote Update: Revisiting the P&G-Trian Contest

Frequently touted for its absolute scale, it seems fitting that the knock-down, drag-out fight between Trian and P&G is slated to continue into extra rounds. Indeed, P&G is the largest firm to ever face a proxy contest, and the cash reportedly invested by the two sides tops all prior campaigns. As widely reported, management’s quick […]

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Coordinating Compliance Incentives

The notion that corporations must develop effective ethics and compliance programs is uncontroversial. Earlier this month, Deputy Attorney General Rod Rosenstein explained that the “sophistication of compliance measures and tools that we see today regularly exceed the measures that were in place ten years ago.” In part, this increased sophistication may be credited to the […]

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SEC’s Proposed Modernization of Regulation S-K

On October 11, 2017, at the first open meeting under Chairman Jay Clayton’s tenure, the SEC proposed amendments to modernize and simplify certain disclosure requirements in Regulation S-K. The proposed amendments are largely consistent with the recommendations in the SEC’s FAST Act Report to Congress in November 2016 (the “Report”).  The rulemaking proposal is intended […]

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Weekly Roundup: October 20–26, 2017

Securities Cases to Watch this Term at the Supreme Court Posted by Brad S. Karp, Paul, Weiss, Rifkind, Wharton & Garrison LLP, on Friday, October 20, 2017 Tags: Class actions, Dodd-Frank Act, Fraud-on-the-Market, Rule 10b-5, Section 10(b), Securities enforcement, Securities fraud, Securities litigation, Securities regulation, SLUSA, Supreme Court, Whistleblowers Director Networks, Turnover, and Appointments Posted by Luc Renneboog, Tilburg University, and Yang Zhao, Newcastle University, on Friday, October 20, […]

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Environmental and Social Proposals in the 2017 Proxy Season

The Conference Board recently released a report that reviews the key environmental and social (E&S) proposals in the 2017 proxy season. The report provides details on some of the most prominent topics, including topics which received high levels of shareholder support and topics that have seen notable changes in support levels compared to previous years. […]

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The Hart-Scott-Rodino Act’s First Amendment Problem

The Hart-Scott-Rodino Antitrust Improvements Act (“HSR Act”) is a centerpiece of federal antitrust law. Designed to aid enforcement of Clayton Act Section 7, which prohibits mergers and acquisitions that “may … substantially … lessen competition” or “tend to create a monopoly,” the statute requires the prospective acquirer of an issuer’s voting securities exceeding a certain […]

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FPI Director Oversight over Related Party Transactions

Investors and regulators in the current corporate governance environment have increased their focus on companies’ transactions with their directors, senior management, and other related persons. These related-party transactions raise special disclosure issues for non-US companies, known as foreign private issuers (FPIs), that are listed on US stock exchanges. FPIs may engage in related-party transactions that […]

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The Rise of Investor-Centric Activism Defense Strategy

Shareholder activism is often thought of in binary terms: activist v. company, dissident nominees v. company directors. Media coverage dramatically frames the “showdown” of prominent and press-savvy activists taking on companies as both sides seek the upper hand on the way to the ballot box. While an “us vs. them” mentality makes for a compelling […]

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Preferred-Stock Minority Investments in the Private Equity Context

When purchasing a company, private equity sponsors typically use a combination of debt and equity to fund the purchase price. When structuring a transaction, private equity sponsors may invest all or a portion of their equity capital in the form of preferred stock or issue preferred stock to minority investors if sufficient debt is not […]

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