The proposed Department of Government Efficiency (“DOGE”) in incoming President Donald J. Trump’s administration promises an ambitious agenda of “regulatory rescission, administrative reductions and cost savings” with the goal of “mass head-count reductions across the federal bureaucracy” by July 4, 2026.[1] Many questions remain about the logistical and legal paths to accomplish these objectives.
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SEC Announces Enforcement Results for Fiscal Year 2024
The Securities and Exchange Commission announced on November 22 that it filed 583 total enforcement actions in fiscal year 2024 while obtaining orders for $8.2 billion in financial remedies, the highest amount in SEC history.
The 583 enforcement actions represent a 26 percent decline in total enforcement actions compared to fiscal year 2023. Of those…
Debevoise & Plimpton Discusses Key Considerations for the 2024 Annual Reporting Season
As November comes to an end, the busy annual reporting and proxy season begins for many public companies. In this Client Update, we highlight key considerations for public companies when preparing their annual reports on Form 10-K or Form 20-F, including a new exhibit filing requirement for insider trading policies. For a checklist covering these…
White & Case Discusses SEC 2025 Priorities: AI, Cybersecurity, and Crypto
On October 21, 2024, the US Securities and Exchange Commission (“SEC”) Division of Examinations (“Examination Division”) announced its 2025 Examination Priorities (“Report”). Investment advisers and broker-dealers should ensure that policies, procedures and surveillance efforts related to these priorities address concerns outlined in the Report.
The Examination Division conducts inspections of entities registered with the SEC,…
Gibson Dunn Discusses New U.S. Outbound Investment Regulations
On October 28, 2024, the U.S. Department of the Treasury issued final regulations implementing an outbound investment control regime targeting AI, semiconductors, and quantum computing investments involving China that raise national security concerns. The regulations’ prohibitions and reporting requirements go into effect on January 2, 2025.
Outbound investment regulations have arrived, and with them the…
Debevoise & Plimpton Reviews 2024 Proxy Season
The 2024 proxy season was characterized by a high volume of shareholder proposals submitted to companies, including proposals relating to topical issues such as artificial intelligence (“AI”) and political lobbying and spending. In addition, the number of no-action requests submitted to the Securities and Exchange Commission (the “SEC”) increased compared to 2023. Based on our…
Gibson Dunn Offers Securities Litigation 2024 Mid-Year Update
This update provides an overview of the major developments in federal and state securities litigation since our Securities Litigation 2023 Year-End Update. A recent NERA Economic Consulting (NERA) study provides an overview of recent developments in filings. This section highlights several notable trends.
Filing Trends
Figure 1 below reflects the federal filing rates from…
Will Large Language Models Propel Financial Statement Analysis Into a New Era?
Since the introduction of ChatGPT, large language models (LLMs) have completed a variety of tasks with impressive results, from summarizing complex documents to conducting sentiment analysis to extracting relevant information. But are LLMs up to even greater challenges like, say, making informed financial decisions?
In a new paper, we explore whether LLMs can handle financial…
How Board Networks Reinforce Corporate Innovation
In recent years, technological advances and structural shifts have catalyzed a surge in corporate investments in research and development (R&D), intellectual property, and other intangible assets. These developments reflect the growing importance of innovation-driven growth in the modern economy. In this context, R&D investments, by their nature, generate ideas that are “non-rival,” meaning that their…
Wachtell Lipton Offers Summer Takeaways in SEC Enforcement
With the Labor Day holiday now behind us, it is a good time to review the SEC’s active enforcement docket and to look ahead to likely areas of continuing enforcement attention as we head into the fall. The record over the past few months reflects a continuing emphasis on certain major program areas, along with…