Public Company Advisory: SEC Snapshots Fourth Quarter 2025

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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 fourth quarter of 2025 are listed below (in chronological order and with embedded links to the source materials):

• Spencer Stuart published its annual report on the composition, governance practices, and refreshment trends of S&P 500 boards (October 8, 2025)
• The SEC Division of Corporation Finance updated its guidance for Division activities during a government shutdown (October 9, 2025)
• The Center for Audit Quality (CAQ) released an updated External Auditor Assessment Tool (October 9, 2025)
• The California Air Resources Board (CARB) released a draft template for reporting Scope 1 and Scope 2 emissions under SB 253 (October 10, 2025)
• Broadridge published its 2026 proxy design handbook (October 10, 2025)
• Broadridge published a report on the 2025 proxy season (October 13, 2025)
• EY published a study of AI and cybersecurity disclosures (October 14, 2025)
• FW Cook published a report on executive perquisites (October 14, 2025)
• The PCAOB published a study on financial restatements and auditor turnover (October 15, 2025)
• Glass Lewis released the results of its annual policy survey (October 22, 2025)
• PwC published the results of its annual corporate director survey (October 22, 2025)
• The SEC Division of Corporation Finance issued a statement regarding its role in the Rule 14a-8 process for the 2025-2026 proxy season (November 17, 2025)
• CARB updated its FAQs on climate reporting requirements (November 17, 2025)
• The Conference Board published a study on board composition and governance practices at US public companies (November 17, 2025) (free registration required)
• CARB held its third virtual public workshop on California’s climate reporting laws (November 18, 2025) (see Maynard client alert)
• Cornerstone Research published a report on SEC enforcement activity (November 19, 2025)
• ISS announced updates to its 2026 benchmark proxy voting policies (November 25, 2025)
• PwC updated its financial statement presentation guide (December 1, 2025)
• Chairman Atkins delivered a speech titled “Revitalizing America’s Markets at 250” supporting disclosure reform and increased accommodations for smaller public companies (December 2, 2025)
• Glass Lewis published its voting policies for 2026 (December 4, 2025)
• The SEC announced it dismissed its civil enforcement action against SolarWinds and its Chief Information Security Officer (December 4, 2025)
• The CAQ and Ideagen Audit Analytics released the 12th annual Audit Committee Transparency Barometer Report (December 4, 2025)
• ISS published a study on AI-related shareholder proposals (December 4, 2025)
• The SEC Division of Corporation Finance updated its Financial Reporting Manual (December 5, 2025)
• CARB released proposed regulations addressing compliance with SB 253 (December 9, 2025)
• The White House issued an Executive Order addressing proxy advisory firms (December 11, 2025)
• The SEC Division of Trading and Markets issued a no-action letter to the Depositary Trust Company (DTC) addressing DTC’s pilot version of tokenization services (December 11, 2025)
• KPMG published a report on tariff disclosures in quarterly reports (December 11, 2025)
• PwC published its 2026 capital markets outlook report (December 12, 2025)
• New York State issued final regulations requiring large emitters to disclose their greenhouse gas emissions beginning in 2027 (December 15, 2025)
• Nasdaq filed a rule proposal to expand trading hours for listed equities and exchange-traded products to 23 hours a day, five days a week (December 15, 2025)
• The Holding Foreign Insiders Accountable Act (Section 8103 of the Defense Authorization Act for Fiscal Year 2026) was enacted, eliminating the exemption to the Section 16(a) reporting requirements for directors and officers of foreign private issuers (December 18, 2025)
• The SEC published a notice of filing and immediate effectiveness of proposed rule change to provide Nasdaq with limited discretion to deny initial listing to certain companies (December 19, 2025)

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.