Monthly Archives: August 2017

August 17, 2017

Links to Exhibits: How to Link to A Very Old Exhibit

We’ve blogged several times since the SEC adopted a rule requiring companies to link to exhibits in their filings. My latest blog predicted that we would see guidance from Corp Fin ahead of the September 1st effective date of that rule. At this point, that is starting to look unlikely.

That last blog noted that there are a number of open questions that folks are wondering about. For example, how does one link to an exhibit in a 30-year old registration statement that was filed as one gigantic ASCII file? In this blog, Bass Berry’s Jay Knight notes that he has received an informal answer to this question from the Corp Fin Staff.

Here’s the relevant excerpt from that blog:

Based on recent informal Staff discussions relating to this question, we were instructed that the filer should hyperlink to the ASCII filing containing the exhibit and clearly identify the hyperlinked exhibit that is being incorporated by reference from the ASCII filing.

By way of example, the hyperlink description could look something like this: “Articles of Incorporation (incorporated by reference to Exhibit 3.1 to the Form S-1 Registration Statement filed with the SEC on XX XX, XXX) (File No. XXX-XXXXXX).”

Alternatively, the registrant could voluntarily choose to re-file the old exhibit with the present filing.

Revenue Recognition & Lease Accounting: Microsoft’s Messaging

Recently, John blogged about how Microsoft is one of the early adopters of the FASB’s new revenue recognition standard. Microsoft is also early adopting FASB’s new lease accounting standard.

Just a few weeks ago, Microsoft held a call for with investors to explain the impact of the transition to the new standards – see the presentation slides, transcript and audio archive.

Federal Reserve: “Board Duties” Proposal

Recently, the Federal Reserve Board proposed new principles for boards. The proposal comes on the heels of the Treasury’s related report – which itself is based on the Administration’s “Executive Order on Core Principles for Regulating the U.S. Financial System.” For more, see the memos posted in our “Financial Institutions” Practice Area

Broc Romanek

August 16, 2017

Should Passive Shareholders Not Be Allowed to Vote?

Recently, Liz blogged about an article that indicates that some investors that are considered “passive” may be more on auto-pilot than some would think. Now we have a paper that wants passive funds to be restricted from voting in an effort to preserve the role of informed investors as a force for managerial discipline.

Recently, John blogged about a Rivel Research study that asked institutional investors what they thought of regulatory reform efforts. Now Rivel is conducting a similar study – but this time with companies providing their views. If you participate in this Rivel survey, you get a free copy of the final report…

NYSE Revises Dividend & Stock Distribution Notice Requirements

Here’s the intro from this Cooley blog:

On Monday, the SEC approved a rule change that amended the NYSE Manual to require listed companies to provide notice to the NYSE at least ten minutes before making any public announcement with respect to a dividend or stock distribution, irrespective of the time of day, even when the notice is outside of NYSE trading hours (rather than limited to the hours of 7:00 A.M. and 4:00 P.M. as in the prior rule). Bring your sleeping bags, NYSE staff: the NYSE indicated that “it intends to have its staff available at all times to review dividend or stock distribution notices immediately upon receipt, regardless of the time or date the notices are received….The Exchange staff will contact a listed company immediately if there is a problem with its notification.”

Transcript: “FCPA Considerations in M&A”

We have posted the transcript for our recent webcast: “FCPA Considerations in M&A.”

Broc Romanek

August 15, 2017

Climate Change: Vanguard to Provide More On Its Voting Record

As we’ve blogged (also see this article), Vanguard recently received a shareholder proposal requesting additional disclosure about its climate change voting record – but Vanguard announced yesterday that it had negotiated the proposal’s withdrawal (also see this interview with Vanguard’s Glenn Booraem).

Here’s the key excerpt from Vanguard’s announcement:

Walden’s request also coincided with our plans for more comprehensive reporting on our Investment Stewardship activities; the first iteration of our expanded reporting will be published later this month, coincident with the annual filing of our proxy voting records. This report will feature deeper discussion of our thinking on climate risk and gender diversity on boards (as two issues on which we expect continuing focus), as well as expanded anecdotal discussion of specific engagements, voting rationale, and vote decisions.

Audit Reports: Comparison of PCAOB & International Standards

Check out this nifty comparison of the PCAOB’s and IAASB’s standards for the audit report. Note that the PCAOB’s standard is still awaiting the SEC’s approval, as noted in this blog

Tomorrow’s Webcast: “Structuring, Negotiating & Litigating Public Deals – Has the Pendulum Moved?”

Tune in tomorrow for the webcast – “Structuring, Negotiating & Litigating Public Deals: Has the Pendulum Moved?” – to hear Greenberg Traurig’s Cliff Neimeth, Richards Layton’s John Zeberkiewicz and Richards Layton’s Mark Gentile analyze how recent Delaware case law and statutory changes are influencing the way that M&A deals are structured, negotiated and litigated.

Broc Romanek

August 14, 2017

Tomorrow’s Pre-Conference Webcast: “Pay Ratio Workshop – What You (Really) Need to Do Now”

For those registered for the upcoming “Pay Ratio & Proxy Disclosure Conference,” tune in tomorrow – 2 pm eastern (audio archive goes up when the program ends; transcript available in a week or so) – for the second in a series of three monthly webcasts that serve as a pre-conference: “Pay Ratio Workshop: What You (Really) Need to Do Now.” The first webcast was on July 20th (transcript & audio archive available); the third webcast is September 27th.

The speakers for tomorrow’s webcast are:

Mark Borges, Principal, Compensia
Keith Higgins, Partner, Ropes & Gray
Scott Spector, Partner, Fenwick & West

Register Now: This is the only comprehensive conference devoted to pay ratio. Here’s the registration information for the “Pay Ratio & Proxy Disclosure Conference” to be held October 17-18th in Washington DC and via Live Nationwide Video Webcast. Here are the agendas – 20 panels over two days. Register today.

Conflict Minerals: Many Companies Still Filing Reports

Here’s an excerpt from this blog by Cooley’s Cydney Posner:

Development International has posted its most recent “Conflict Minerals Benchmarking Study,” analyzing the results of filings for the 2016 filing period. The study looked at filings submitted by the 1,153 issuers that had filed conflict minerals disclosures as of July 10, 2017. The number of issuers filing disclosures for 2016 reflected a decline of 5.6% compared to 2015. Most interesting, however, is that, notwithstanding statements from Corp Fin, echoed by the Acting SEC Chair at the time, advising companies that they would not face enforcement if they filed only a Form SD and did not include a conflict minerals report, the vast majority of companies continued to file conflict minerals reports.

PCAOB: The Board’s Half-Full or Half-Empty?

The PCAOB occasionally struggles to have a full complement of its five-member Board – similar to any federal agency – but this time, it’s perhaps taken to an extreme. On Friday, SEC Chair Clayton issued this statement that includes this blurb:

SOX provides that the PCAOB is governed by a Board of five members — two of whom must be certified public accountants, and three of whom must not be — serving for staggered five-year terms. Today, of the five PCAOB Board seats, one is vacant, two are held by members whose terms have expired, and one is held by a member whose term will expire in two months.

PCAOB Chair Jim Doty – whose term has expired – is helping to look for his successor. Jeanette Franzel’s term is also expired, and Steven Harris’s term will end in two months. Lewis Ferguson’s term ends in October 2019. So lots of changes are coming to the PCAOB’s cast of Board members…

Broc Romanek

August 11, 2017

Initial Coin Offerings: Will the SEC’s Position Slow Them Down?

We’ve posted oodles of memos about the SEC’s Section 21(a) Report on initial coin offerings that John recently blogged about.

A number of articles written since the SEC’s Report indicate that the SEC’s position might not slow down the use of ICOs – instead, they will be offered to accredited and/or off-shore investors. For example, see this Reuters article – and this TechCrunch interview. This trend started even before the SEC’s Report was issued.

In fact, the Reuters article seems to indicate that some ICOs are going forward even with US investors that aren’t accredited. Either these companies are total gunslingers – or they don’t know what a shot across the bow looks like. Or more likely, they don’t believe the SEC’s position is a strong one. Or perhaps the word hasn’t gotten out.

As noted in this Gibson Dunn blog, Delaware Governor Carney recently signed Senate Bill 69 into law – effective August 1st – amending Delaware’s General Corporation Law to allow companies to utilize blockchain technology to maintain and distribute certain corporate records.

ICOs: What Are the Open Issues?

There certainly have been a ton of law firm memos on the SEC’s Section 21(a) Report on initial coin offerings! Some of them spot open issues, including this Cleary Gottlieb blog. Love that the Howey test & the whole “definition of securities” analysis is getting so much play! Securities law geek heaven…

The United States is not the only country grappling with this issue. This Morrison & Foerster memo examines a similar situation in Singapore…

ICOs: What Types Are There?

In this blog, Steve Quinlivan reviews the type of ICOs that have been conducted so far…

Speaking of algorithms, this memo discusses how management & boards should be analyzing algorithmic risks…

Broc Romanek

August 10, 2017

The Diminishing Influence of the US Chamber of Commerce

This recent Washington Post article describes the current state of the US Chamber of Commerce. Here’s an excerpt:

And in an era that allows virtually unlimited independent political spending, they can form their own more focused, and perhaps more effective, associations. Many lobbyists who represent companies individually think the Chamber has taken on the lumbering character of its aging building, a 92-year-old limestone edifice lined with Corinthian columns overlooking the White House.

“If there was a time in the past when they needed the Chamber for access to the White House, that’s kind of gone,” said a public affairs consultant who had worked with three Fortune 500 companies that have weighed leaving the Chamber. “Companies have the tools to create coalitions of like-minded firms on issues that are important to them.”

Here’s a note that I received from a member in response: “They are losing influence with the White House because Trump and the Bannon wing would rather listen to the Breitbart crowd and the alt-right. My guess is the generals high up in the administration also have no time for the Chamber. However, the Chamber still has good access to members of Congress since members rely more on that constituency. The Chamber’s future may lie with the state governors and legislatures, which is where there is some possibility of real work getting accomplished. Washington has become a three-branch circus.”

DERA’s 315-Page Report: Access to Capital & Market Liquidity

A few days ago, the SEC’s Division of Economic and Risk Analysis (DERA) published this 315-page report describing trends in primary securities issuance and secondary market liquidity, and assessing how those trends relate to post-crisis regulatory reforms. The report was requested by Congress as part of the 2016 appropriations process.

The report includes a survey &analysis of recent academic literature, as well as original analyses drawn from publicly available databases and non-public regulatory filings. The report examines the issuance of debt, equity and asset-backed securities, as well as activity and liquidity in U.S. Treasuries, corporate bonds, single-name credit default swaps, and bond funds. Specifically, the report identifies trends for unregistered offerings – including Reg D and Regulation Crowdfunding, as well as fixed income transactions, fixed income quotations, and broker-dealer financial positions…

Pay Ratio: Survey About Your Disclosure Intentions

We have posted a new anonymous “Quick Survey about Pay Ratio Disclosure” to learn whether folks are intending to disclose the bare minimum about pay ratio – or whether they intend to provide explanations, alternate ratios, carve-outs, etc. This is different than our recent survey about pay ratio readiness. Please take 10 seconds to participate…and also complete this “Quick Survey on Director Compensation.”

For those registered for the upcoming “Pay Ratio & Proxy Disclosure Conference,” tune in next Tuesday, August 15th for the second in a series of three monthly webcasts that serve as a pre-conference: “Pay Ratio Workshop: What You (Really) Need to Do Now.” The first webcast was on July 20th (transcript & audio archive available); the third webcast is September 27th.

The speakers for next Tuesday’s webcast are:

Mark Borges, Principal, Compensia
Keith Higgins, Partner, Ropes & Gray LLP
Scott Spector, Partner, Fenwick & West LLP

Register Now: This is the only comprehensive conference devoted to pay ratio. Here’s the registration information for the “Pay Ratio & Proxy Disclosure Conference” to be held October 17-18th in Washington DC and via Live Nationwide Video Webcast. Here are the agendas – 20 panels over two days. Register today.

Broc Romanek

August 9, 2017

Ratings Principles: Now Coming to Cybersecurity

Recently, a group of more than 40 prominent banks, retailers & tech companies released these “Principles for Fair & Accurate Securities Ratings.” Here’s a teaser from this BakerHostetler blog (also see this Reuters article):

The principles are designed to promote fair and accurate cybersecurity ratings – in response to the recent emergence of several ratings companies that collect and analyze publicly accessible data to analyze a company’s cybersecurity risk posture. The ratings are increasingly used by insurers – as well as in M&A and other business decisions.

The data for risk ratings is typically collected without the target company’s knowledge and comes from a variety of sources – e.g. hackers’ forums, darknet data, Internet traffic stats, port-scanning tools & open-source malware intelligence sources. Ratings companies then use proprietary methodologies and algorithms to analyze the data and assign a grade.

Importantly, however, cybersecurity ratings have the potential for being inaccurate, incomplete, unverifiable and unreliable – if, for example, the source data is inaccurate or the methodology doesn’t account for risk mitigations in place at a company.

The principles developed by the consortium were designed to increase confidence in and the usability of fair and accurate cybersecurity ratings by addressing the potential problems. The principles were modeled after the Fair Credit Reporting Act.

We don’t know if cybersecurity risk ratings will become anywhere near as important as credit ratings – but keep them on your radar. The signatories to the principles include Aetna, American Express, Bank of America, Chevron, Eli Lilly, Fannie Mae, FICO, Goldman Sachs, Home Depot, Honeywell, JP Morgan, Microsoft, State Street & lots of other big names.

When is “Hacking Disclosure” Required in SEC Filings?

By now, most companies have a cyber incident response plan – which should include contacting a securities lawyer to evaluate disclosure requirements. As outlined in this Goodwin memo, these decisions continue to depend on a fact-specific materiality analysis:

What is “material” ends up being far less clear, and there is plenty of room for a public company to determine in good faith that a specific cyber incident does not require separate disclosure. Where the obligation is unclear, a company’s reluctance to disclose is understandable: Disclosure may highlight vulnerabilities, and will bring unwelcome attention from customers, regulators and others. The plaintiffs’ bar will also circle, smelling the possibility of a class action, and they will not view the company and its managers as the victims.

While the SEC won’t second-guess a good-faith analysis, they also won’t shy away from investigating disclosure lags – see this WSJ article about whether Yahoo’s data breach should’ve been reported sooner to investors.

The memo identifies factors affecting disclosure decisions – such as the significance of other notice obligations, existing risk factors & potential remediation costs. Since the decision will probably have to be made quickly, it’s not a bad idea to create a decision tree in advance. Our “Cybersecurity Disclosure Checklist” is a good starting point, and check out this blog as well…

Cyber Insurance: Is Everyone Doing It?

According to this AM Best article, companies paid over $1 billion in cyber insurance premiums in 2016 – but the market might grow to $20 billion by 2020! Of course, this depends on whether last year’s 34.7% increase in premiums is a sustainable trend versus a one-off response to noteworthy breaches.

The article also notes ongoing uncertainty among insurers about pricing & risk exposure – so maybe some companies are getting bargains. But standalone policies now account for about 70% of coverage – which (from insurers’ perspectives) is improving the accuracy of their evaluations.

See this “Insurance Journal” article for intel on providers & other trends. And see this article about how Senator Mark Warner has sent a letter to the SEC outlining his concerns about more transparency if market participants get hacked…

Liz Dunshee

August 8, 2017

Survey: Venture-Backed IPO Practices

Only 42 venture-backed companies went public in the United States in 2016 – including eight incorporated outside the United States – making it the most challenging year by number of IPOs and by aggregate offering amount raised since the recessionary times of 2009. The average offering amount per IPO in 2016 was only $77.3 million—the lowest average since 2003.

Venture-backed IPOs in 2017 are on pace to surpass the levels reached in 2016, both in number of IPOs and aggregate offering amount raised. In the first six months of this year, 31 venture-backed companies have gone public in the United States, including seven incorporated outside the United States. And the Snap IPO in March raised $3.4 billion—nearly $70 million more than all venture-backed IPOs in 2016 combined. Here’s the latest “Venture-Backed IPO Survey” from Gunderson Dettmer, focusing on key governance & disclosure items.

Of the 34 venture-backed companies that the firm reviewed:

– All are incorporated in Delaware

– 52.9% listed on the Nasdaq Global Market, 32.4% listed on the Nasdaq Global Select Market, 11.8% on the Nasdaq Capital Market and 2.9% on the New York Stock Exchange

– Average time from incorporation to IPO was just over eight years

– Average time from initial registration statement submission to the SEC to pricing the IPO was nearly 8.5 months

– 30% included a directed share program component in the IPO

– Only seven of the companies completed follow-on offerings in 2016

Companies were also taking advantage of Jobs Act accommodations – 100% submitted a confidential registration statement & 88% provided two years of audited financials.

Voting Rights: CalPERS Wins “Dual-Class” Suit

Recently, CalPERS notched a win for investors in the battle over “dual-class” voting structures. The pension giant sued Interactive Corp last year when it attempted to create a new non-voting class of stock that would have given perpetual voting control to the board chair – despite the fact that he owned only 8% of outstanding economic rights.

After months of litigation, the company has abandoned its proposed issuance. Here’s an excerpt from this “Harvard Law” blog:

By shedding the light of litigation on IAC’s non-voting share plan, CalPERS achieved a significant victory for shareholders’ core right to vote. This result should make founders and controllers considering copying the trend of non-voting stock issuances think twice – as institutional investors will act decisively to defend and assert their right to vote when faced with these threats. Such protective actions will continue to promote open and responsive capital markets, and the long-term value creation that comes with them.

Tomorrow’s Webcast: “Controlled Companies – Trends & Unique Issues”

Tune in tomorrow for the webcast – “Controlled Companies: Trends & Unique Issues” – to hear Jane Freedman, Dorsey’s Cam Hoang and Davis Polk’s Sophia Hudson discuss the unique issues involved with controlled companies.

Liz Dunshee

August 7, 2017

Climate Disclosures: New G20 Recommendations

Last year, we blogged about the Financial Stability Board’s formation of an industry-led “Task Force on Climate-Related Financial Disclosures.” Now, the Task Force has issued its 74-page final report – Recommendations of the Task Force on Climate-related Financial Disclosures – along with supporting materials – which provide a standardized framework & guidance for voluntary climate-related financial risk disclosures in SEC filings.

While lots of climate change disclosure principles exist – here’s one of our many earlier blogs – this Task Force is significant because it was organized by the G20 – which coordinates national financial authorities & standard-setting bodies, including the SEC. Also, the press release highlights that companies with a combined market cap of $3.5 trillion – and financial institutions responsible for assets of $25 trillion – have committed to support the recommendations.

Here’s an excerpt from this Davis Polk blog:

The recommendations boil down to four thematically related areas: governance, strategy, risk management, and metrics & targets.

Governance: organizations are encouraged to disclose their governance around climate-related risks and opportunities, including board oversight and management’s role in assessing and managing these risks and opportunities.

Strategy: one of the centerpieces of the recommendations and likely the most controversial and difficult, is the TCFD recommendation that organizations disclose the actual and potential material impacts of climate-related risks and opportunities on their businesses, strategy and financial planning, including (i) climate-related risks identified in the short-, medium- and long-term (not defined); (ii) the impact of such risks on the organizations’ businesses, strategy and financial planning; and (iii) the resilience of the organizations’ strategy under different climate-related scenarios including a 2ºC or lower scenario. Importantly, the TCFD is not recommending any specific 2ºC scenario, instead providing criteria to aid each organization’s design of its own 2ºC scenario.

Risk Management: the TCFD recommends disclosure of processes for identifying, assessing and managing climate-related risks and a description of how these processes are integrated into the organization’s overall risk management.

Metrics & Targets: if material, the TCFD recommends organizations disclose (i) the metrics used to assess climate-related risks and opportunities in line with their strategy and risk management processes; (ii) their Scope 1, 2, and 3 greenhouse gas emissions (defined as direct emissions, indirect emissions from consumption of purchased power and other indirect emissions through the organization’s value chain) and related risks; and (iii) the targets used and the organization’s performance against such targets.

While the framework is useful, it’s also intentionally ambitious – and practices will continue to evolve. Check out our “Climate Change” Practice Area for up-to-date guidance – and tune in for our October 10th webcast: “E&S Disclosures: The In-House Perspective.”

The World’s First Climate Ratings for Funds

Recently, ISS teamed with UK & EU organizations to launch “Climetrics” – the first climate rating system for funds. Here’s an excerpt from the ISS announcement:

The rating – symbolized by “green leaves” issued on a scale of one to five– will enable investors to gauge and compare the climate impact of investments in funds and potentially encourage growth in climate-responsible fund products.

The equity fund market – worth more than €3 trillion in Europe – could be a significant lever for mitigating climate change. But, despite fast-growing institutional and customer demand for climate-conscious investing, to-date no rating system has allowed investors to compare funds’ climate-related impacts.

Climetrics will rate European funds based on the climate change impact of their portfolio holdings – as well as the asset managers’ application of climate impact as an investment & governance factor and the funds’ ESG policies. Investors can see the ratings for free on

Preparing For – & Responding To – Climate Change Proposals

Last month, we blogged about a possible trend: climate change proposals passing with historic levels of support. This recent Weil blog lays out suggestions for companies and boards who’ve received climate and sustainability proposals & engagement requests – or who want to prepare in advance.

Conveniently, Annex A of Weil’s blog also summarizes and links to the voting policies for a number of institutional investors. Check out this blog from Dorsey’s Cam Hoang for info on the pressure that these investors are getting to change their E&S policies.

Visit our “ESG/Social Responsibility” Practice Area for even more resources on this topic…

Liz Dunshee

August 4, 2017

Voting: “Passive” Institutional Investors Become Even More So?

Over the years, we’ve blogged about the extent to which ISS influences voters at institutional investors (here’s an example). Different studies (or anecdotes) show different things – and the debate continues. This recent article from “Proxy Insight” (pg. 6) indicates that some investors that are considered “passive” may be more on auto-pilot than some would think. Here’s an excerpt from that article:

Looking at Proxy Insight’s ISS Vote Comparator table, for most of these investors this is not a right they often feel compelled to exercise. The majority of them vote 99-100 percent in accordance with ISS. Of course, this correlation makes the investors a reliable source for discerning ISS recommendations.

However, we thought it would be interesting to look at what issues would make auto-voters override the voting recommendations of ISS, providing some insight into the proposals that matter most to these investors. To do this we have taken the ten largest investors by assets under management who vote in accordance with ISS, and analyzed those proposal types where they override most frequently. These include say on pay, the re-/election of directors and auditor ratification.

Say on pay is not only one of the most frequently voted issues for auto-voters, but is also usually near the top (see Table 3) when it comes to the disparity between investor voting and ISS recommendations. This is unsurprising, given that say on pay is one of the most contentious proxy voting topics, which is seemingly never out of the news.

However, as Table 1 illustrates, even on contentious issues auto-voters receive a correlation with ISS that ranges in the high 90s. Moreover, the lower correlation on exclusively ISS against recommendations (Against recs (%)) indicates that the auto-voters are more passive than ISS, overriding the proxy adviser in order to vote with management. Other proposals near the top of the list include the approval of stock option plans and restricted stock plans.

Note that the meaning of “passive” depends on one’s perspective. To some, it’s voting with management. But others could say that breaking with ISS for the say-on-pay vote is the definition of “active” – given the time & effort required for an institutional investor to override a default voting policy.

Conference Hotel Nearly Sold Out: “Pay Ratio Conference”

If you plan to attend in Washington DC (rather than by video webcast), be warned that the Conference Hotel for our “Pay Ratio & Proxy Disclosure Conference” on October 17-18th is nearly sold out. The Conference Hotel is the Washington Hilton, 1919 Connecticut Ave NW, Washington, DC 20009. Reserve your room online or call 202.483.3000 to make your reservations.

Be sure to mention the “Proxy Disclosure Conference” to get a discounted rate. If you have any difficulty securing a room, please contact us at or 925.685.9271.

ISS Policy Survey: Pay Ratio & More

Yesterday, ISS opened up its “Annual Policy Survey,” which is being undertaken in two parts this year:

1. Governance Principles Survey – Initial, high-level survey on high-profile topics including “one-share, one vote,” pay ratio disclosures, the use of virtual meetings, and board gender diversity. In this survey, ISS is asking companies (i) how they plan to analyze pay ratios and (ii) what is their view on how shareholders should use pay ratio disclosures. This survey closes on August 31st.

2. Policy Application Survey – More expansive portion that can be accessed at the end of the initial portion, allowing respondents to drill down into key issues by market and region as well as by topics such as responsible investment, takeover defenses and director compensation. This survey closes October 6th.

After analysis of the survey responses, ISS will open a comment period for all interested market participants on the final proposed changes to their policies as always…

Next Pay Ratio Webcast: Tune in on Tuesday, August 15th for the second of our monthly pre-conference webcasts on pay ratio: “Pay Ratio Workshop: What You (Really) Need to Do Now.” The speakers for the August 15th webcast are:

Mark Borges, Principal, Compensia
Keith Higgins, Partner, Ropes & Gray LLP
Scott Spector, Partner, Fenwick & West LLP

For those registered for our comprehensive “Pay Ratio & Proxy Disclosure Conference“, we have posted the transcript for our July 20th webcast. The third webcast is on September 27th.

Liz Dunshee