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HTMLCalifornia Attorney General Launches Complaint Form to Report CalOPPA Violations
Françoise Gilbert; Greenberg Traurig, LLP;
Legal Alert/Article
October 26, 2016, previously published on October 19, 2016
When the California Privacy Protection Act (CalOPPA) (Bus. & Prof. Code §§22575-22579) was enacted in 2003 it became the first state law to specifically require operators of commercial websites or mobile apps that collect certain information about consumers to conspicuously post a...

 

HTMLUK Criminal Finances Bill Tackles Money Laundering and Corruption
Lisa Navarro, Marie-José van der Heijden; Greenberg Traurig Maher LLP;
Legal Alert/Article
October 26, 2016, previously published on October 19, 2016
The Criminal Finances Bill (the Bill) had its first reading in the House of Commons on 13 October 2016. The Bill is a key part of the UK government's ongoing program to improve its ability to tackle money laundering and corruption, recover the proceeds of crimes, and counter terrorist financing. It...

 

HTMLUK to Implement Fourth Money Laundering Directive, Presenting an Opportunity for the Gaming Sector to Provide Input
Lisa Navarro; Greenberg Traurig Maher LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
The current EU Money Laundering and Terrorist Financing (ML/TF) measures are contained in the Third Money Laundering Directive (3MLD). 3MLD was implemented into UK law by the Money Laundering Regulations 2007, the Proceeds of Crime Act 2002, and the Terrorism Act 2000. These Regulations promote a...

 

HTMLEnd of Tandy Representations
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
On Oct. 5, 2016, the Division of Corporation Finance announced that, effective immediately, they will no longer require issuers to include “Tandy” representations in responses to SEC comment letters. Tandy representations, which have been required in all such response letters since...

 

HTMLSEC Sanctions Company for Misrepresentation of Performance Metrics
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
In the last week of September, the SEC Enforcement division brought three separate enforcement actions against companies for failure to timely report issuances of unregistered equity securities on Form 8-K and Form 10-Q. The actions are similar to the 10 enforcement actions brought by the SEC in...

 

HTMLRecently Issued Accounting Standards - The SEC’s View on Disclosure
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
The SEC staff recently addressed best practices for financial statement disclosure in periods leading up to the adoption of recently issued accounting standard updates, or ASUs. In particular, the SEC staff commented on the application of Staff Accounting Bulletin (SAB) Topic 11.M “Disclosure...

 

HTMLSEC Sanctions Three Issuers for Failing to Timely Disclose Equity Issuances
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
In the last week of September, the SEC Enforcement division brought three separate enforcement actions against companies for failure to timely report issuances of unregistered equity securities on Form 8-K and Form 10-Q. The actions are similar to the 10 enforcement actions brought by the SEC in...

 

HTMLDelaware Chancery Court Clarifies that Disclosure Claims Should Be Brought Pre-Closing
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
In an opinion issued Sept. 28, 2016, the Court of Chancery of Delaware clarified its position that claims challenging the sufficiency of proxy solicitation disclosures should be brought during the pre-closing period of a merger transaction in order to insure a fully informed vote of the...

 

HTMLRecent SEC Comment Letter Provides Insight to SEC’s Current Views on Non-GAAP Measures
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
A recently released SEC comment letter provides issuers additional insight into the views of the staff of the Division of Corporation Finance on the use of certain non-GAAP financial measures. The comment letter, issued in July 2016, questioned whether certain of the issuer’s non-GAAP...

 

HTMLSEC Update on Proxy Access
Greenberg Traurig LLP;
Legal Alert/Article
October 20, 2016, previously published on October 17, 2016
On Sept. 27, 2016, the staff of the Division of Corporation Finance issued three no-action letters in response to requests to exclude shareholder proxy access proposals on the basis that the companies had already “substantially implemented” the proposals.

 


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