Christodoulos Kaoutzanis

Dec 26, 2023 | lexology.com | Christopher Cummings |David Huntington |Brian Janson |Luke Jennings |Christodoulos Kaoutzanis |John Kennedy | +3 more

On December 19, 2023, the U.S. Court of Appeals for the Fifth Circuit vacated the SEC’s share repurchase disclosure rule, which would have required public companies to disclose their reasons for repurchasing shares, and to collect daily repurchase data and file it quarterly. The Fifth Circuit had previously held that the SEC’s adoption of the rule violated the Administrative Procedure Act, and had remanded the matter to the SEC and directed it to correct the noted deficiencies within 30 days.

Dec 20, 2023 | lexology.com | John Carlin |David Huntington |Luke Jennings |Christodoulos Kaoutzanis |John Kennedy |Jeannie S. Rhee | +5 more

On July 26, 2023, the Securities and Exchange Commission adopted amendments to Form 8-K to add new Item 1.05, which requires public companies to disclose certain information regarding any material cybersecurity incident within four business days of an assessment that the incident is material.[1] New Item 1.05 of Form 8-K took effect for most public companies on December 18, 2023 (smaller reporting companies have until June 15, 2024 to comply).

Aug 2, 2023 | lexology.com | Jonathan H. Ashtor |H. Christopher Boehning |John Carlin |Christopher Cummings |David Huntington |Brian Janson | +6 more

The SEC has adopted new disclosure requirements to enhance and standardize public company disclosures regarding cybersecurity risk management and incident reporting. Companies will be required to disclose material cybersecurity incidents within four business days on Form 8-K, and to provide annual disclosure regarding their cybersecurity governance and risk management.

Feb 23, 2023 | lexology.com | Christopher Cummings |David Huntington |Brian Janson |Luke Jennings |Christodoulos Kaoutzanis |John Kennedy | +2 more

The SEC has adopted amendments (available here) to Rule 15c6-1 under the Securities Exchange Act of 1934, as amended, to shorten the securities settlement cycle for most transactions to T+1 (from T+2), and for firm commitment offerings priced after 4:30 p.m. to T+2 (from T+4).