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

What the Allergan/Valeant Story Teaches About Staggered Boards 

Until March 2015, I was the Executive Vice President and General Counsel of Allergan, Inc. For much of 2014 my job was to address the hostile bid launched by Valeant and Pershing Square to acquire Allergan. With that perspective, I followed with interest the debate surrounding staggered boards, and in particular the success of institutional […]

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The Changing Dynamics of Governance and Engagement

As anticipated, the 2015 proxy season has been the “Season of Shareholder Engagement” for U.S. public companies. Activist attacks, high-profile battles for board seats, and shifting alliances of major investors and proxy advisors have created an environment in which shareholder engagement is near the top of every well-advised board’s to-do list. There is no shortage […]

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SEC Charges Computer Sciences Corporation & Former Executives With Accounting Fraud

On June 5, 2015, the Securities and Exchange Commission (“SEC”) entered into settled administrative cease-and-desist proceedings with Computer Sciences Corporation (“CSC”) and some of its former executives due to the company’s alleged manipulation of financial results and concealment of problems with the company’s largest contract. [1] Among other things, CSC agreed to pay a $190 […]

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Angels and Venture Capitalists: A Match Made in Heaven?

Are angel investors and venture capitalists friends or foes? Are they synergistic partners in the process of funding entrepreneurial value creation? Or are they distinct funding mechanisms where entrepreneurs have to decide which camp they want to be part of? In a series of two recent papers (Friends or Foes? The Interrelationship between Angel and […]

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Are Public Companies Required to Disclose Government Investigations?

For many public companies, the first issue they have to confront after they receive a government subpoena or Civil Investigative Demand (“CID”) is whether to disclose publicly that they are under investigation. Curiously, the standards for disclosure of investigations are more muddled than one would expect. As a result, disclosure practices vary—investigations are sometimes disclosed […]

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Employment Protection and Takeovers

Cost reductions in the pursuit of economies of scale and scope are commonly believed to be a major driver—and a key source of synergies—in corporate takeovers. Restructuring the workforce, largely in the form of layoffs, is presumed to be one of the primary channels through which such cost reductions are obtained. However, despite the central […]

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Delaware Court Relies Exclusively on Merger Price in Appraisal Action

In a recent appraisal proceeding, the Delaware Court of Chancery concluded that the company had engaged in a thorough sales process, and therefore found that it was appropriate to determine fair value of the company’s stock by relying exclusively on the merger price less net synergies. The court found that a discounted cash flow (or […]

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The UK’s Final Bonus Compensation Rule

On June 23rd, the UK’s Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) [1] finalized a joint bonus compensation rule that was proposed last July. While the industry (including subsidiaries and branches of US banks in the UK) had hoped for a more lenient approach, the final rule generally retains the proposal’s stringent […]

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“Pay Versus Performance” Rule Proposed by SEC Under Dodd-Frank

“We are drowning in information, while starving for wisdom.” —E.O. Wilson [1] On April 29, the Securities and Exchange Commission announced its proposal to add a new Item 402(v), captioned “Pay versus Performance,” to Regulation S-K. [2] The SEC announced the proposed rule pursuant to Dodd-Frank Section 953(a). [3] Section 953(a) directs the SEC to […]

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Third Circuit Provides Guidance on Excluding Shareholder Proposals

On Monday, the U.S. Court of Appeals for the Third Circuit released its opinion in Trinity Wall Street v. Wal-Mart Stores, Inc. [1] The Court had issued an earlier order, without an opinion, that Wal-Mart could exclude Trinity’s Rule 14a-8 shareholder proposal relating to the sale of firearms with high-capacity magazines from Wal-Mart’s proxy materials […]

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