The SEC published its Spring 2024 Reg-Flex Agenda. Most notably, and in comparison to the Fall 2023 Agenda:
· Issuance of a proposed rule on human capital management disclosure was pushed back from April 2024 to October 2024.
· Issuance of a proposed rule on corporate board diversity disclosure was pushed back from October 2024 to April 2025.
· Final amendments to Rule 14a-8 are slated for April 2025 rather than April 2024 as reflected on the Fall 2023 Agenda. (Society comment letter here).
· Adoption of a final “EDGAR Next” rule is targeted for October 2024. We reported on the proposed rule here.
Proxy plumbing and conflict minerals rulemakings remain on the SEC’s long-term agenda. We most recently reported on the status of proposed Dodd Frank-prompted rulemaking relating to incentive-based compensation at certain financial institutions here.
Notably, the agendas were developed well before the recent Supreme Court “Chevron deference” and other rulings that may impact the content and scope of proposed and final agency rulemakings.
Resources on specific rulemaking topics are available on our Practical Resources pages.