Author: Nicole H. Strydom

Nicole H. Strydom

Nicole Strydom helps clients achieve their business goals in the fields of securities law, mergers and acquisitions and general corporate law. She assists public companies with respect to their capital markets activities, including equity and debt offerings, and ongoing disclosure and compliance issues, including periodic and current reporting and proxy statement requirements. Nicole has also served clients on stock and asset deals in a broad range of sizes, as well as on a variety of general corporate matters.

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SEC Updates Guidance on Expiring Confidential Treatment Orders

SEC Updates Guidance on Expiring Confidential Treatment Orders

On September 9, the SEC’s Division of Corporation Finance updated its guidance to outline three alternatives for handling an expiring confidential treatment order (“CTO”): 1) If the contract continues to be material but the previously redacted information is no longer confidential: refile the unredacted exhibit. 2) If the contract continues to be material, and the previously redacted information continues to be confidential, request to extend...

Impact of “Test-the-Waters” Reform Debated

Impact of “Test-the-Waters” Reform Debated

As we previously noted, in February, the SEC proposed expanding its “test-the-waters” accommodation from emerging growth companies (EGCs) only to all issuers via a new Rule 163B and related amendments. This accommodation would enable all issuers to engage in “test-the-waters” communications with certain institutional investors regarding a contemplated registered securities offering prior to, or following the filing of a registration statement related to such offering....

Recent Developments in Auditor Tenure and Independence

Recent Developments in Auditor Tenure and Independence

Last month, over 35% of General Electric Co.’s shareholders voted against ratification of KPMG LLC as GE’s auditor. This high level of opposition (for some context, last year’s votes against KPMG were at a mere 5.7%) comes in the wake of GE’s recent accounting issues and criticism from proxy-advisory firms. More specifically, the SEC is currently investigating some of GE’s accounting practices, including its need...