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

U.S. Enforcement Policy and Foreign Corporations

We recently reported on a new U.S. Department of Justice policy which expanded expectations for corporate cooperation in white collar investigations. While the initial wave of attention given to the DOJ pronouncement focused on U.S. companies, this new policy is also important for all companies with operations in the U.S. or whose activities otherwise bring […]

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Posted in International Corporate Governance & Regulation, Legislative & Regulatory Developments, Practitioner Publications, Securities Litigation & Enforcement, Securities Regulation | Tagged , , , , , , , , , , , , | Comments Off on U.S. Enforcement Policy and Foreign Corporations

Open-End Fund Liquidity Risk Management and Swing Pricing

The Commission will consider a recommendation of the staff to propose a new rule and amendments designed to strengthen the management of liquidity risks by registered open-end investment companies, including mutual funds and exchange-traded funds (or ETFs). Regulation of the asset management industry is one of the Commission’s most important responsibilities in furthering our mission […]

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Posted in Derivatives, Legislative & Regulatory Developments, Practitioner Publications, Regulators Materials, Securities Regulation, Speeches & Testimony | Tagged , , , , , , , , , , | Comments Off on Open-End Fund Liquidity Risk Management and Swing Pricing

Is Institutional Investor Stewardship Still Elusive?

The idea that institutional investors should behave as active, long-term oriented “stewards” has caught on globally. Five years after the launch of the landmark UK Stewardship Code, counterparts can be found on four continents (see Figure 1). When the UK code was promulgated, I argued that institutional investor stewardship was an elusive quest due to, […]

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Posted in Academic Research, Banking & Financial Institutions, Comparative Corporate Governance & Regulation, Executive Compensation, Institutional Investors | Tagged , , , , , , , , , , , | Comments Off on Is Institutional Investor Stewardship Still Elusive?

In re Dole Food Company, Inc. and the Cost of Going Private

On August 27, 2015, Vice Chancellor Laster authored a widely anticipated opinion providing valuable guidance on steering clear of a flawed process in a going-private transaction. David H. Murdock, the CEO and Chairman of Dole and a 40% shareholder, and C. Michael Carter, the General Counsel, President and COO of Dole and characterized as Murdock’s […]

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Posted in Accounting & Disclosure, Court Cases, Mergers & Acquisitions, Practitioner Publications | Tagged , , , , , , , , , , , , | Comments Off on In re Dole Food Company, Inc. and the Cost of Going Private

A New Paradigm for Corporate Governance

Recently, there have been three important studies by prominent economists and law professors, each of which points out serious flaws in the so-called empirical evidence being put forth to justify short-termism, attacks by activist hedge funds and shareholder-centric corporate governance. These new studies show that the so-called empirical evidence omit important control variables, use improper […]

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Posted in Academic Research, Comparative Corporate Governance & Regulation, Corporate Elections & Voting, Empirical Research, Practitioner Publications | Tagged , , , , , | Comments Off on A New Paradigm for Corporate Governance

Opportunism as a Managerial Trait

In trading their firms’ stocks, insiders must balance the profits of informed trading before news, the scrutiny by regulators that such trading can engender, formal policy restrictions by firms of insider trading activities, and diversification and liquidity motivations for selling shares after vesting of equity-based compensation. This mixture of motivations and constraints makes it is […]

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Posted in Academic Research, Accounting & Disclosure, Empirical Research, Securities Regulation | Tagged , , , , , , , , , , , , , | Comments Off on Opportunism as a Managerial Trait

Individual Accountability for Corporate Wrongdoing

On September 9, 2015, the Department of Justice (“DOJ”) issued a new policy memorandum, signed by Deputy Attorney General Sally Yates, regarding the prosecution of individuals in corporate fraud cases—”Individual Accountability for Corporate Wrongdoing” (“the Yates Memorandum”). The Yates Memorandum has been heralded as a sign of a new resolve at DOJ, and follows a […]

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Posted in Legislative & Regulatory Developments, Practitioner Publications, Securities Litigation & Enforcement, Securities Regulation | Tagged , , , , , , , , , , | Comments Off on Individual Accountability for Corporate Wrongdoing

Peer Effects of Corporate Social Responsibility

Corporate social responsibility (CSR) has increasingly become a mainstream business activity—ranging from voluntarily engaging in environmental protection to increasing workforce diversity and employee welfare—although standard economic theories predict that it should be rather uncommon (Benabou and Tirole, 2010; Kitzmueller and Shimshack, 2012). The neoclassical economic paradigm usually considers CSR as unnecessary and inconsistent with profit […]

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Posted in Academic Research, Accounting & Disclosure, Comparative Corporate Governance & Regulation, Corporate Social Responsibility, Empirical Research | Tagged , , , , , , , , , , , | Comments Off on Peer Effects of Corporate Social Responsibility

Title VII and Security-Based Swaps

In the first half of 2015, the Securities and Exchange Commission (the “SEC”) finalized or proposed a number of rules relating to security-based swaps (“SBSs”). These include final and proposed rules on the reporting and public dissemination of security-based swaps, proposed rules on security-based swap transactions arranged, negotiated or executed by U.S.-based personnel of a […]

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Posted in Accounting & Disclosure, Banking & Financial Institutions, Financial Regulation, International Corporate Governance & Regulation, Legislative & Regulatory Developments, Practitioner Publications, Securities Regulation | Tagged , , , , , , , , , , , , , | Comments Off on Title VII and Security-Based Swaps

Federal Court Dismisses Madoff Investors’ Claim

In a significant decision addressing claims arising out of Bernard Madoff’s Ponzi scheme, the U.S. District Court for the Middle District of Florida has dismissed federal securities and other claims asserted by Madoff investors. Dusek v. JPMorgan Chase & Co., No. 2:14-cv-184 (M.D. Fla. Sept. 17, 2015). The decision applies and enforces key principles of […]

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Posted in Banking & Financial Institutions, Court Cases, Financial Regulation, Practitioner Publications, Securities Litigation & Enforcement | Tagged , , , , , , , | Comments Off on Federal Court Dismisses Madoff Investors’ Claim