TheCorporateCounsel.net

Had a blast at our week of conferences last week! The speakers did a great job. Interviewing Congressman Mike Oxley was a career highlight (and luckily, my days as ‘Billy Broc’ Oxley never came up). I’m particularly thankful to Faruqi & Faruqi’s Juan Monteverde for coming and being willing to answer many direct questions about the motivations and nature of his proxy disclosure lawsuits (stay tuned for more from Juan). Juan is a character and definitely added spice to the conference (next year’s conference? Vegas in late September!). Here is a pic of us together:

SEC Provides Additional Guidance on Form 13F Confidential Treatment Requests

In this blog, Leonard Street’s Steve Quinlivan notes:

The SEC Division of Investment Management has issued additional guidance that is meant to assist institutional investment managers that wish to request confidential treatment, or CT requests, for certain information reported on Form 13F. The guidance elaborates on the types of information that the SEC believes might be relevant in evaluating a confidential treatment request for an Ongoing Acquisition/Disposition Program in a Reportable Security.

In 1998 the SEC provided detailed guidance to Form 13F filers that might be making CT Requests for an Ongoing Acquisition/Disposition Program. In particular, the 1998 letter elaborated on five categories of information that Form 13F requires to be provided in a CT Request for an Ongoing Acquisition/Disposition Program in a Reportable Security, in order for the SEC to be able to make an informed decision about whether delaying or preventing public disclosure is necessary or appropriate in the public interest and for the protection of investors or to maintain fair and orderly markets.

In reviewing CT requests for Ongoing Acquisition/Disposition Programs since issuing the 1998 letter, the SEC staff has further identified information, for each of the five categories, that is particularly helpful in reaching an informed decision on the CT requests. The new guidance spells out the additional information in detail.

More on “The Mentor Blog”

We continue to post new items daily on our blog – “The Mentor Blog” – for TheCorporateCounsel.net members. Members can sign up to get that blog pushed out to them via email whenever there is a new entry by simply inputting their email address on the left side of that blog. Here are some of the latest entries:

– Ontario Securities Commission Consults on Board Diversity
– Debate Begins on PCAOB’s Audit Report Proposal
– Federal Court: Skeptical Whether Dodd-Frank Extraterritorial Jurisdiction Provision Overturns Morrison in Government Actions
– Notes: ABA’s FINRA Corporate Financing Rules Subcommittee
– Survey: Two-Thirds of CEOs Don’t Receive Outside Leadership Advice – But Nearly All Want It

– Broc Romanek