Public Company Advisory: SEC Snapshots First Quarter 2026

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The members of Maynard Nexsen’s Public Company Advisory Practice counsel public companies and companies aiming to become public on the full range of matters shaping their governance and operation in the public markets. As a continued service to our clients, we provide a quarterly summary of important developments affecting public companies. Top trending items for the first quarter of 2026 are listed below (in chronological order and with embedded links to the source materials):

• President Trump issued an Executive Order directing the SEC to revisit and potentially amend Rule 10b-18 to prohibit use of the safe harbor for share repurchases by underperforming defense contractors (January 7, 2026)
• JPMorgan’s asset management division announced that it is severing ties with ISS and Glass Lewis and using a new internal AI platform (January 7, 2026)
• BlackRock published its 2026 voting guidelines for benchmark policies (January 7, 2026)
• S. Court of Appeals for the Ninth Circuit heard oral arguments in Chamber of Commerce v. Sanchez, lawsuit challenging California’s climate disclosure laws, SB 253 and SB 261 (January 9, 2026)
• Vanguard published its 2026 voting policies (January 12, 2026)
• SEC Chair Atkins released a statement on reforming Regulation S-K (January 13, 2026)
• Nasdaq filed a rule proposal to set a minimum continued listing amount of $5 million in market value of listed securities for the Nasdaq Global and Capital Markets (January 13, 2026)
• Labrador Transparency published a study of shareholder engagement disclosure trends (January 13, 2026)
• The New York Attorney General sued a former CEO for misuse of a Rule 10b5-1 plan for insider trading (January 15, 2026)
• The SEC approved the PCAOB’s 2026 budget with significant reductions (January 22, 2026)
• The SEC Division of Corporation Finance updated its Compliance & Disclosure Interpretations (now known as Corporation Finance Interpretations, or “CFIs”) on Securities Act sections, Securities Act rules, proxy rules, tender offer rules and Regulation S-K, which included, among other topics, relaxing the deadline to conduct Rule 14a-13 broker searches (January 23, 2026)
• The SEC Division of Corporation Finance provided interpretive guidance to BofA Securities on “group” status under Section 13(d) in respect of certain over-the-counter derivative positions (January 23, 2026)
• The SEC Division of Corporation Finance published FAQs on Form D (January 23, 2026)
• NYSE published its annual listed company compliance guidance (January 27, 2026)
• The SEC Division of Corporation Finance updated certain of its CFIs relating to notices of exempt solicitation, which included the Staff objecting to the practice of “voluntary” exempt solicitations (January 27, 2026)
• The SEC Division of Corporation Finance issued a statement on tokenized securities (January 28, 2026)
• Wells Fargo’s wealth and investment management division announced that it is severing ties to ISS and Glass Lewis and instead using in-house resources to make voting decisions (January 28, 2026)
• NYSE proposed amendments to the initial listing standards for the NYSE American exchange (January 29, 2026)
• The SEC announced the appointment of a new chair and four new board members to the PCAOB (January 30, 2026)
• The SEC Division of Corporation Finance posted updated guidance on its operations in advance of a potential government shutdown (January 30, 2026)
• The UK Financial Conduct Authority (FCA) issued proposed new mandatory UK Sustainability Reporting Standards (January 30, 2026)
• The U.S. District Court for the District of Columbia ruled on the constitutionality of Section 13(d) of the Exchange Act in SEC v. Elon Musk (February 3, 2026)
• The SEC announced that it would begin to suspend filings with incorrect or incomplete structured filing fee‑related information (XBRL), and referred filers to its How-to-Guide on Preparing an Inline XBRL Filing Fee Exhibit (February 6, 2026)
• The SEC Division of Corporation Finance updated its CFIs on Securities Act forms, Securities Act rules, tender offer rules and going private rules (February 11, 2026)
• SEC Chair Atkins provides testimony in a Senate Banking Committee Hearing suggesting that some prediction markets could fall under the SEC’s jurisdiction (February 12, 2026)
• The SEC Division of Corporation Finance updated its CFIs on Securities Act rules and Regulation Crowdfunding (February 17, 2026)
• Nasdaq proposed new rules to allow it to delist the securities of certain issuers for which the SEC has implemented a temporary trading suspension (February 20, 2026)
• The Committee of Sponsoring Organizations (COSO) published guidance on achieving effective internal control over generative AI (February 23, 2026)
• Ideagen published a 20-year study on trends in IPOs (February 23, 2026) (free registration required)
• The SEC updated its Enforcement Manual (February 24, 2026)
• Vanguard settled Texas lawsuit alleging that Vanguard, State Street and BlackRock conspired to drive up coal prices through coordinated ESG-driven market manipulation (February 25, 2026)
• The California Air Resources Board (CARB) approved the adoption of the California Greenhouse Gas Reporting and Climate Financial Risk Disclosure Initial Regulation (February 26, 2026) (see Maynard client alert)
• ISS published a report on early proxy season trends (February 26, 2026) (free registration required)
• The Delaware Supreme Court ruled that SB 21’s amendments to the Delaware General Corporation Law (“DGCL”) in March 2025, including new and amended DGCL “safe harbor” procedures for transactions between corporations and their controlling stockholders, directors and officers, were constitutional (February 27, 2026)
• The SEC adopted final rule and form amendments reflecting the requirements of the Holding Foreign Insiders Accountable Act for Section 16 reporting by certain insiders of foreign private issuers (February 27, 2026)
• The SEC issued an order exempting insiders of certain foreign private issuers (FPIs) from the new Section 16 reporting rules under the Holding Foreign Insiders Accountable Act (HFIAA) (March 5, 2026)
• Nasdaq launched a new stock exchange, Nasdaq Texas, LLC, previously known as Nasdaq BX, Inc. (March 5, 2026)
• The SEC Division of Corporation Finance updated its CFIs on Rule 701 under the Securities Act rules (March 6, 2026)
• The SEC Division of Corporation Finance posted FAQs on the new Section 16 reporting rules for insiders of FPIs (March 9, 2026)
• The Department of Justice released a new Corporate Enforcement Policy (March 10, 2026)
• Cornerstone Research published a report on SEC enforcement activity (March 10, 2026)
• The SEC and CFTC announce that they have entered into a historic Memorandum of Understanding to guide coordination and collaboration between the two agencies and their regulatory frameworks (March 11, 2026)
• The Council of Institutional Investors updated its corporate governance guidelines (March 12, 2026)
• The SEC granted no-action relief to directors and officers of FPIs located in the geographic region directly affected by the ongoing Iran conflict (March 13, 2026)
• Deloitte and the Society for Corporate Governance published a study on board crisis management trends (March 13, 2026)
• The SEC proposed amendments to Exchange Act Rule 15c2-11 in order to confirm that the rule’s application is to be limited to equity securities (March 16, 2026)
• The SEC adopted amendments to the EDGAR Filer Manual (March 16, 2026)
• The SEC announced Enforcement Division Director Judge Margaret A. Ryan’s resignation (March 16, 2026)
• The SEC’s Division of Economic and Risk Analysis (DERA) published a new report on updated statistics on initial public offerings (IPOs) (March 17, 2026)
• The SEC issued an interpretation – jointly with the CFTC – clarifying how the federal securities laws apply to certain crypto assets (March 17, 2026)
• The SEC approved a Nasdaq rule on trading in tokenized securities (March 18, 2026)
• The SEC Division of Corporation Finance issued a new Securities Act Form CFI on ATM shelf registrations (March 19, 2026)
• The SEC Division of Corporation Finance issued CFIs on asset-backed issuers (March 19, 2026)
• Shareholder advocacy groups sued the SEC and its Commissioners over its revised shareholder proposal no-action policy (March 19, 2026)
• Canadian securities regulators announced the adoption of semi-annual financial reporting pilot (March 19, 2026)
• The Vanguard Group, Inc. filed approximately two thousand “exit” Schedule 13G amendments giving effect to its internal realignment, with initial Schedule 13G filings in the process of being made by affiliated investment advisors (March 26-30, 2026)
• COSO released Corporate Governance: Guiding Principles for Board Oversight (March 31, 2026)
• Rowe Price released its 2026 proxy voting guidelines (March 31, 2026)
• Equilar published a study on AI disclosures (March 31, 2026)
• CFTC Director of Enforcement David Miller announces CFTC enforcement priorities, which will include insider trading in prediction markets based on misappropriated information (March 31, 2026)
• The PCAOB released a request for public comment seeking input regarding the PCAOB’s strategic priorities (March 31, 2026)

For additional information about any of the above developments, or to discuss any questions that you may have, please contact a member of Maynard Nexsen’s Public Company Advisory Group.

This Client Alert is for information purposes only and should not be construed as legal advice. The information in this Client Alert is not intended to create and does not create an attorney-client relationship.