June 22, 2004

Completed Survey on Blackout and

We have wrapped up our survey on blackout and window period practices, with a healthy response of 159. Three-quarters have not changed their periods, while 15% expanded them and 8% reduced them. 10% intend to change their periods soon, while 21% are mulling it over (and 20% did it recently) – and 50% are comfortable with what they have. There also are stats on what types of blackout and window periods are currently being used – so check out the results!

New Survey on Disclosure Committees!

With “real-time” disclosure bearing down on us, I expect many companies will be rethinking the composition of their disclosure commmittees – answer 4 simple questions in our new survey on disclosure committees and we shall see if I am right or wrong…

Google Revises S-1 Again

I don’t know why but I get a chuckle out of today’s mainstream business press that theorizes on what type of Corp Fin comments led to Google filing an Amendment No. 2 to S-1, where it revised its risk factors and moved the founders’ letter (regarding why its business is so unique) to the middle of the prospectus. My favorite risk factor essentially states retail investors don’t know what they are doing and will be buying a majority of the shares issued in this IPO, so the stock price might tank afterwards…

Chairman Donaldson Speaks

Last week, SEC Chairman Donaldson gave a speech at the Directors College at Stanford Law School, where he spoke about various Commission initiatives and accomplishments, including the controversy over the shareholder access proposal.