Public Company Advisory: SEC Snapshots Second 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 second quarter of 2025 are listed below (in chronological order and with embedded links to the source materials):

• The SEC published a notice of an immediately effective NYSE rule change addressing listing fees (April 2, 2025)
• Deloitte published a study on disclosure trends in the 2024 reporting season (April 2, 2025)
• Georgeson published a report on trends in shareholder activism (April 2, 2025) (free registration required)
• The SEC published a Notice of Filing of Application for Registration as a National Securities Exchange by Texas Stock Exchange LLC (April 4, 2025)
• Paul Atkins was confirmed by the Senate as the new SEC chair (April 9, 2025)
• The SEC approved Green Impact Exchange, LLC (GIX) as a national securities exchange (April 11, 2025)
• The SEC Division of Corporation Finance released a total of seven Compliance and Disclosure Interpretations (CDIs) on Exchange Act rules and Exchange Act forms (April 11, 2025)
• BDO published a white paper on financial reporting considerations for tariffs (April 23, 2025)
• Vanguard reported results of a study of over 1,000 investors, which showed a strong interest in participating in the proxy voting process (April 24, 2025)
• The SEC Division of Corporation Finance released two new CDIs and revised 22 existing CDIs addressing Rule 10b5-1 (April 25, 2025)
• The SEC Division of Economic and Risk Analysis (DERA) published new data and analysis on key market areas including public issuers and exempt offerings (April 28, 2025) 
• EY published a study of IPO activity in the first quarter (April 29, 2025)
• The SEC approved an amendment to the NYSE Listed Company Manual addressing stockholders requirements for listing (May 2, 2025)
• Intelligize published a report about public company disclosures addressing U.S. tariff policy (May 7, 2025)
• Glass Lewis published a study on trends in executive perquisites (May 7, 2025) (free registration required)
• The International Federation of Accountants (IFAC) and the AICPA released a five year study on trends in sustainability disclosure and assurance (May 12, 2025) (free registration required)
• Texas adopted amendments to its Business Organizations Code to codify the business judgment rule (May 14, 2025)
• Ideagen published a report about public company auditors (May 15, 2025) (free registration required)
• The PCAOB published a report on conversations with audit committee chairs (May 15, 2025)
• Semler Brossy published a study on the results of say-on-pay shareholder votes (May 15, 2025)
• The SEC Division of Corporation Finance released a new CDI and revised an existing CDI addressing asset-backed issuers (May 16, 2025)
• The SEC approved a NYSE rule change addressing the payment of exchange fees and compliance listing standards (May 20, 2025)
• The PCAOB published guidance on auditing accounting estimates (May 21, 2025)
• ISS published a proxy season review (May 22, 2025)
• The Committee of Sponsoring Organizations of the Treadway Commission (COSO) in collaboration with the National Association of Corporate Directors (NACD) published a proposed corporate governance framework (May 27, 2025) (see Maynard client alert for additional discussion)
• The California Air Resources Board (CARB) held a virtual public workshop on California’s climate reporting laws (May 29, 2025) (see Maynard client alert for additional discussion)
• KPMG published a disclosure checklist for sustainability disclosures (May 29, 2025)
• The Department of Justice published new guidelines for the enforcement of the Foreign Corrupt Practices Act (June 9, 2025)
• Toppan Merrill published its 2026 proxy statement style guide (June 11, 2025) (free registration required)
• The SEC released a notice of withdrawal of 14 proposed rules, including one related to shareholder proposals (June 12, 2025)
• The SEC published a concept release on foreign private issuer eligibility (June 12, 2025)
• The NYSE and J.P. Morgan published a white paper on board composition and structure (June 12, 2025)
• The SEC adopted an updated EDGAR Filer Manual (June 16, 2025)
• Ideagen published a study on public company restatements (June 16, 2025) (free registration required)
• PwC published a director’s guide on sustainability and ESG oversight (June 17, 2025)
• The SEC issued two new CDIs and withdrew one CDI related to legal proceedings disclosure (June 20, 2025)
• Texas enacted a law that imposes new regulations on proxy advisory firms (June 21, 2025)
• Georgeson published a report on the 2025 proxy season (June 24, 2025) (free registration required)
• The SEC hosted a roundtable discussing executive compensation disclosure requirements (June 26, 2025)
• Glass Lewis announced forthcoming changes to its quantitative pay-for-performance assessments for the 2026 proxy season (June 27, 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.