Yesterday, the SEC issued a press release stating that it would begin posting Corp Fin and IM comment letters and filer responses on its own website. No more FOIA requests – and no more using paid subscription services to dig these out.
This process will commence for any filings made after August 1st that are selected for review – and no correspondence will be posted until after 45 days of a completed review. Based on the language in the press release, it seems fair to expect that the Staff will now routinely seek Tandy letter representations.
And of course, confidential treatment requests are more important than ever. The SEC is interested in receiving “suggestions on how to make the transition and process work efficiently, and ask that any comments be provided promptly.”
Understanding Obstruction of Justice
The successful prosecutions of Martha Stewart and Frank Quattrone highlight the increased risk corporate executives face from “obstruction of justice” and similar offenses – learn more in my interview with Michael Peregrine and Russell Hayman on Guide to Avoiding “Obstruction of Justice” Liability.
How to Understand the Benefits Provided by SERPs
And so begins my daily blogging about the unique resources about responsible compensation practices available on CompensationStandardsConference.com – my first is this practice pointer from Marian Tse of Goodwin Procter on How to Understand the Benefits Provided by SERPs.