It will be important to the comment process for commenters to submit their views on the Proposal. A well-developed administrative record—including from those who support the Proposal—helps inform the Commission’s deliberations and supports the durability of any final action.
SEC Proposes Amendments to Streamline and Recalibrate Filer Status Determinations and Related Reporting Obligations
The SEC is seeking comments on a variety of aspects of the proposed amendments, including on whether any additional accommodations for SNFs may be appropriate.
SEC Proposes Broad Amendments to Registered Offering Framework
The proposals reflect the most coordinated effort in two decades to address concerns about the shrinking public-company population, the high fixed costs of public-company status for smaller issuers, and the friction that state-level review imposes on unlisted registered offerings.
Update: May 20, 2026 Order Granting Additional Directors and Officers of Certain Foreign Private Issuers an Exemption from Section 16 (a) Reporting
On May 20, 2026, the Securities and Exchange Commission (SEC) updated its grant of exemptive relief from Section 16(a) reporting requirements for directors and officers of foreign private issuers (FPIs) organized in a “qualifying jurisdiction,” who are subject to a “qualifying regulation[1]”. Three additional “qualifying jurisdictions” were added: Australia, India and Singapore.
Gibson Dunn ESG: Risk, Litigation, and Reporting Update (April 2026)
We are pleased to provide you with Gibson Dunn’s ESG Risk, Litigation, and Reporting update covering the following key developments during April 2026. Please click on the links below for further details.
SEC Proposes Amendments to Permit Optional Semiannual Reporting by Public Companies
Companies evaluating the alternatives would need to consider a number of factors addressed in this update, including investor expectations and any reporting obligations under debt agreements.
Gibson Dunn ESG: Risk, Litigation, and Reporting Update (March 2026)
We are pleased to provide you with Gibson Dunn’s ESG Risk, Litigation, and Reporting update covering the following key developments during March 2026. Please click on the links below for further details.
SEC Staff Issues Exemptive Relief Allowing 10-Business Day Equity Tender Offers
It is clear that the exemptive relief will provide public and private companies with significantly more flexibility in the structuring and timing of their transactions.
Updated Summary of Director Education Opportunities Now Available
Gibson Dunn’s summary of director education opportunities has been updated as of April 2026. A copy is available at this link. Boards of Directors of public and private companies find this a useful resource as they look for high quality education opportunities.
New Considerations for Reporting Beneficial Ownership by The Vanguard Group in Company Proxy Statements
In June 2025, The Vanguard Group, Inc. (“VGI”) announced plans to establish two wholly owned U.S. investment advisors, Vanguard Capital Management (“VCM”) and Vanguard Portfolio Management (“VPM”), each of which consists of distinct investment management teams and investment stewardship teams to manage various funds. In early January, Vanguard announced that it had completed this internal realignment.