Paul D Hallgren

September 20, 2023 | The Legal Intelligencer

The new disclosure rule, referred to as "pay versus performance" added a wrinkle for companies in advance of the 2023 proxy season. A year has passed since the new disclosure rule was adopted. It is time to take a look back at the first foray into pay versus performance disclosures with an eye to considerations for disclosures in the coming year.

By Katayun I. Jaffari and Paul D. Hallgren

10 minute read

July 31, 2023 | The Legal Intelligencer

This article focuses on the rule changes as they relate to reporting companies that are domestic issuers, even though certain of the amendments apply more broadly, such as to foreign private issuers.

By Mehrnaz Jalali and Paul D. Hallgren

7 minute read

January 24, 2023 | The Legal Intelligencer

The amendments include mandatory cooling-off periods, director and officer certifications, restrictions on multiple overlapping 10b5-1 plans and single-transaction plans and an expanded good faith requirement.

By Mehrnaz Jalali, Kevin Roggow and Paul D. Hallgren

10 minute read

October 31, 2022 | The Legal Intelligencer

The rule requires reporting companies (referred to here as registrants) to provide specific pay versus performance tabular disclosure; a clear description (graphically, narratively or a combination) of the relationship between actual executive compensation paid and financial performance measures; and a tabular list of three to seven financial measures representing the most important financial measures tied to actual compensation.

By Mehrnaz Jalali, Paul D. Hallgren and Rikisha Collins

9 minute read

August 02, 2022 | The Legal Intelligencer

If anybody expected the Securities and Exchange Commission (SEC) to take a summer vacation after making news with its proposed rule on climate disclosures published this spring, they were mistaken. Though the rule changes of summer 2022 may not be quite as bold, they certainly are worth examining. This article summarizes three of those finalized and proposed rule changes.

By Katayun I. Jaffari and Paul D. Hallgren

7 minute read

November 01, 2021 | The Legal Intelligencer

On Sept. 9, the Investor Advisory Committee (the IAC) of the U.S. Securities and Exchange Commission (the SEC) announced recommendations for changes to the rules with respect to Rule 10b5-1 trading plans, those trading plans adopted pursuant to Rule 10b5-1 of the Securities Exchange Act of 1934, as amended (Rule 10b5-1 plans).

By Katayun I. Jaffari, Mehrnaz Jalali and Paul D. Hallgren

8 minute read

November 02, 2020 | The Legal Intelligencer

In September 2020, the Securities and Exchange Commission (SEC) voted 3-2 to adopt amendments to certain disclosure rules for public companies in an effort to modernize information that is presented to investors.

By Katayun I. Jaffari and Paul D. Hallgren

9 minute read

August 05, 2019 | The Legal Intelligencer

Cryptocurrencies and other digital tokens are digital assets that utilize encryption to secure and verify transfers. Markets in cryptocurrencies function without centralized oversight through the use of blockchain technology, which serves as a digital, and in most cases, public, ledger of all cryptocurrency transactions.

By Peter A. Jaslow and Paul D. Hallgren Jr.

8 minute read