Blogs

Shearman & Sterling’s “Lessons for Public Companies’ Disclosure Controls from Recent SEC Enforcement” discusses the recent SEC enforcement action against Activision Blizzard for inadequate disclosure controls and procedures (DC&P) relating to employee complaints (we reported on here), as well as the evolution of relevant SEC DC&P-related enforcement actions. The firm provides guidance to companies on how to reevaluate and bolster their own DC&P in response to the SEC’s heightened focus on controls on a standalone basis without regard to the accuracy of the company’s disclosure.

See “SEC's Activision Smackdown Over 'Risk Factors' Reverberating Through Legal Departments” (Corporate Counsel) and additional resources on our Disclosure Committees and Financial Reporting » Risk Factors pages.

                       This post first appeared in the weekly Society Alert!