TheCorporateCounsel.net

October 17, 2016

Tandy Reps: No Longer Required for Acceleration Requests Too!

As John blogged recently, Corp Fin recently announced that it would no longer require companies to include “Tandy letter” representations in their responses to Staff comments. The question that I got from some members was: “I presume Tandy reps are still required for acceleration requests?” The answer is “no, the Staff no longer seeks Tandy language in acceleration requests.” This is consistent with the rationale for no longer requiring the language in comment response letters…

Here’s a blog by Keith Bishop highlighting that he had questioned whether Tandy reps were enforceable several months ago. By the way, these were called “Tandy” representations because of a position that the SEC Staff took in the mid-’70s against the Tandy Corporation…

Tomorrow’s Webcast: “Virtual-Only Annual Meetings – Nuts & Bolts”

Tune in tomorrow for the webcast – “Virtual-Only Annual Meetings: Nuts & Bolts” – to hear HP’s Katie Colendich, Broadridge’s Cathy Conlon, Ciber’s Sean Radcliffe, GoPro’s Eve Saltman and the Veaco Group’s Kris Veaco as they describe the recent trend towards virtual-only annual meetings, including numerous first-hand accounts of the processes necessary to pull them off.

Political Contributions: Senator Warren Still Red Hot

As noted in this WSJ article, Senator Elizabeth Warren recently wrote this scathing letter to President Obama about SEC Chair White’s failure to conduct political contribution disclosure rulemaking. I have blogged about this saga before…

Here’s a blog by Kevin LaCroix about Warren’s letter, noting it came on the heels of the SEC announcing record Enforcement activity…

Broc Romanek