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

FDIC Lawsuits against Directors and Officers of Failed Financial Institutions

Federal Deposit Insurance Corporation (FDIC) litigation activity associated with failed financial institutions increased significantly in 2013, according to Characteristics of FDIC Lawsuits against Directors and Officers of Failed Financial Institutions—February 2014, a new report by Cornerstone Research. The FDIC filed 40 director and officer (D&O) lawsuits in 2013, compared with 26 in 2012, a 54 […]

Click here to read the complete post
Posted in Banking & Financial Institutions, Boards of Directors, Financial Regulation, Practitioner Publications | Tagged , , , , , , , | Comments Off on FDIC Lawsuits against Directors and Officers of Failed Financial Institutions

Toward a Constitutional Review of the Poison Pill

In a new paper, Toward a Constitutional Review of the Poison Pill, we argue that the state-law rules governing poison pills are vulnerable to challenges based on preemption by the Williams Act. Such challenges, we show, could well have a major impact on the corporate-law landscape. The Williams Act established a federal regime regulating unsolicited […]

Click here to read the complete post
Posted in Academic Research, Mergers & Acquisitions | Tagged , , , , , | Comments Off on Toward a Constitutional Review of the Poison Pill

Corporate “Free Exercise” and Fiduciary Duties of Directors

This Spring, the Supreme Court will decide whether a for-profit corporation can refuse to provide insurance coverage for birth control and other reproductive health services mandated by the Affordable Healthcare Act (or “Obamacare”) when doing so would conflict with “the corporation’s” religious beliefs. Although the main legal issue in Sibelius v. Hobby Lobby Stores, Inc., […]

Click here to read the complete post
Posted in Boards of Directors, Court Cases, Practitioner Publications | Tagged , , , , , , , , | 2 Comments

Enhanced Prudential Standards “First Take”

Our observations on the Federal Reserve’s final rule: 1. Delayed effective date and higher threshold: Foreign Banking Organizations (FBOs) eked out several small victories in the final rule—in particular, the July 2015 compliance date has been pushed to July 2016 and smaller FBOs (i.e., those with under $50 billion in US non-branch assets) are no […]

Click here to read the complete post
Posted in Banking & Financial Institutions, Financial Regulation, Legislative & Regulatory Developments, Practitioner Publications | Tagged , , , , , , , , | Comments Off on Enhanced Prudential Standards “First Take”

SEC Enforcement Year in Review

Marked by leadership changes, high-profile trials, and shifting priorities, 2013 was a turning point for the Enforcement Division of the Securities and Exchange Commission (the “SEC” or the “Commission”). While the results of these management and programmatic changes will continue to play out over the next year and beyond, one notable early observation is that […]

Click here to read the complete post
Posted in Court Cases, Practitioner Publications, Securities Litigation & Enforcement | Tagged , , , , , , , , | Comments Off on SEC Enforcement Year in Review

UK Shareholder Activism: A Toolbox for 2014

Following an increase in shareholder and investor activism beyond pure executive remuneration issues in the United Kingdom (UK) in 2013, with some 25 companies targeted for public campaigns, this post provides a summary of certain principles of English law and UK and European regulation applicable to UK listed public companies and their shareholders that are […]

Click here to read the complete post
Posted in Accounting & Disclosure, Institutional Investors, International Corporate Governance & Regulation, Practitioner Publications | Tagged , , , , , , , , , , | Comments Off on UK Shareholder Activism: A Toolbox for 2014

SEC Institutes Administrative Proceedings Against KPMG For Auditor Independence Violations

On January 24, 2014, the Securities and Exchange Commission (“SEC”) issued an order instituting settled administrative and cease-and-desist proceedings against KPMG LLP (“KPMG”) for violating auditor independence rules in its relationships with affiliates of three of its SEC-registered audit clients. [1] At the crux of the SEC’s order are its findings that: KPMG provided prohibited […]

Click here to read the complete post
Posted in Accounting & Disclosure, Practitioner Publications, Securities Litigation & Enforcement | Tagged , , , , , , | Comments Off on SEC Institutes Administrative Proceedings Against KPMG For Auditor Independence Violations

Addressing Known Risks to Better Protect Investors

I am honored to be here today [February 21, 2014]. This is the sixth time that I have spoken at “SEC Speaks” as a Commissioner. Much has changed since my first “SEC Speaks” in February 2009. At that time, we were in the midst of the worst financial crisis since the Great Depression. Among other […]

Click here to read the complete post
Posted in Practitioner Publications, Regulators Materials, Securities Regulation, Speeches & Testimony | Tagged , , , , , , , | Comments Off on Addressing Known Risks to Better Protect Investors

Dodd-Frank Enhanced Prudential Standards for U.S. Bank Holding Companies and Foreign Banks

Pursuant to Section 165 of the Dodd-Frank Act, the Federal Reserve has issued a final rule to establish enhanced prudential standards for large U.S. bank holding companies (BHCs) and foreign banking organizations (FBOs). U.S. BHCs: The final rule represents the latest in a series of U.S. regulations that apply heightened standards to large U.S. BHCs. As […]

Click here to read the complete post
Posted in Banking & Financial Institutions, Financial Regulation, Legislative & Regulatory Developments, Practitioner Publications | Tagged , , , , , , , , , , | Comments Off on Dodd-Frank Enhanced Prudential Standards for U.S. Bank Holding Companies and Foreign Banks

Financing as a Supply Chain

In our recent NBER working paper, Financing as a Supply Chain: The Capital Structure of Banks and Borrowers, we propose a novel framework to model joint debt decisions of banks and borrowers. Our framework combines the models used by bank regulators with the models used to explain capital structure in corporate finance. This structure can […]

Click here to read the complete post
Posted in Academic Research, Banking & Financial Institutions, Financial Regulation | Tagged , , , , , , , , | Comments Off on Financing as a Supply Chain