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Skadden Discusses New SEC Pay-Versus-Performance Compliance & Disclosure Interpretations

Reynolds Holding

On November 21, 2023, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued eight new Compliance & Disclosure Interpretations (C&DIs), and revised two previously issued C&DIs, relating to the final pay-versus-performance (PVP) disclosure rules adopted last year. Answer: No.

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Cooley’s 2023 Activism Year in Review: Wolfpacks at the Gate

Cooley M&A

However, in 2023 the market logged a notable uptick in “sell-the-company” and “wind-down-the-company” campaigns at clinical stage companies with market capitalizations below cash balances and either very early stage or failed lead programs. Preparing “break the glass” communications plans. Conducting tabletop exercises.