Advisory Proxy Resolutions Are More Important Than Ever

By Karl Sandstrom and Bruce Freed November 20, 2025 by renholding

U.S. Supreme Court Justice Anthony Kennedy observed in the Citizens United decision that shareholders of publicly traded companies could employ the procedures of corporate democracy to ensure that shareholder value was not diverted to political causes and candidates that they …

Simpson Thacher Discusses Use of State-Chartered Trust Companies as Custodians of Crypto

By David Blass, Justin Browder, Anne Choe, Michael Osnato and Michael Passalacqua October 8, 2025 by renholding

In an important development for the asset management industry, the Staff of the SEC’s Division of Investment Management issued a no-action letter to Simpson Thacher in response to our request for confirmation that state-chartered trust companies—which are among the most …

Skadden Discusses SEC Grant of No-Action Relief for Retail Voting Program

By Brian V. Breheny, Raquel Fox, Marc S. Gerber, Elizabeth R. Gonzalez-Sussman and Joshua Shainess September 24, 2025 by renholding

On September 15, 2025, the Staff of the U.S. Securities and Exchange Commission’s (SEC’s) Office of Mergers & Acquisition issued a no-action letter to Exxon Mobil Corporation that allows for the adoption of a retail voting program. To address historically …

Enhanced Scrutiny and the Omnipresent Specter of Political Bias

By Stefan Padfield July 19, 2024 by renholding

Corporate politicization, when companies take sides in our culture war and risk alienating half their potential customers, is a serious concern. Recent examples of companies that have felt its negative impact on shareholder value abound, including Bud Light, Target, and …

Commissioner Peirce Speaks on SEC’s “Secret Law”

By Hester M. Peirce April 12, 2019 by renholding

I would like to begin with the standard disclaimer plus an additional one that ties with the theme of this speech. The views I represent are my own and not necessarily those of the Commission or my fellow Commissioners. The

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Simpson Thacher Discusses SEC Clarifications of Shareholder Proposal Issues

By Karen Hsu Kelley and Shari Ness November 13, 2018 by pss2150

On October 23, 2018, the Division of Corporation Finance of the Securities and Exchange Commission (the SEC) issued new Staff Legal Bulletin 14J[1], following up on previous bulletins clarifying issues arising under Exchange Act Rule 14a-8. The new …

Chapman and Cutler discuss CFTC No-Action Relief for End-Users from the Swaps Clearing Requirement

By William Tueting and Matthew W. Hoffman July 2, 2013 by Jason Parsont

The Division of Clearing and Risk (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”) recently issued no-action relief for certain treasury affiliates within non-financial companies from the clearing requirements of Section 2(h)(1) of the Commodity Exchange Act (“CEA”).

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Morrison and Foerster discusses Issues for Foreign Broker-Dealers under Rule 15a-6

By Hillel Cohn April 12, 2013 by Jason Parsont

Noting the increasingly global nature of financial markets, the U.S. Securities and Exchange Commission (“SEC”) adopted Rule 15a-6 nearly twenty four years ago to facilitate limited access by foreign broker-dealers to customers in the United States. During the years since …

The CLS Blue Sky Blog

Columbia Law School's Blog on Corporations and the Capital Markets

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