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

• Broadridge published an EDGAR Next compliance guide (July 2, 2025)
• President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), introducing sweeping changes to the federal tax laws (July 4, 2025)
• The PCAOB issued staff guidance on audit engagement (July 9, 2025)
• The California Air Resources Board (CARB) published FAQs regarding the implementation of SB 253 (greenhouse gas emissions disclosure) and SB 261 (climate-related financial risk disclosure) (July 9, 2025)
• The SEC Division of Corporation Finance released 18 updated Compliance and Disclosure Interpretations (CDIs) addressing the filing of Schedules 13D and 13G (July 11, 2025)
• Deloitte published a white paper on directors’ skills in the current business environment (July 15, 2025)
• ISS published a study on reincorporation proposals (July 16, 2025)
• The SEC designated George R. Botic to serve as Acting Chair of the PCAOB (July 21, 2025)
• EY published a 2025 proxy season review (July 23, 2025)
• The Conference Board published a report of trends in diversity disclosures (August 1, 2025) (free registration required)
• Intelligize published a report on disclosures of AI risks (August 6, 2025)
• DF King published a report on the 2025 proxy season (August 11, 2025) (free registration required)
• The SEC announced a new statistics and data visualization page with statistics and graphics on key elements of the capital markets (August 13, 2025)
• The SEC announced that Judge Margaret “Meg” Ryan has been named Director of the Division of Enforcement (August 21, 2025)
• CARB held a virtual public workshop on California’s climate reporting laws (August 21, 2025) (see Maynard client alert for additional discussion)
• Nasdaq proposed changes to its listing standards related to listing securities in connection with a business combination with an OTC-listed SPAC (August 22, 2025)
• Nasdaq proposed changes to its listing standards related to the minimum bid price requirement (August 22, 2025)
• The SEC issued a fee rate advisory for fiscal 2026 (August 25, 2025)
• Ideagen published a 20-year study of SOX404 disclosures (August 26, 2025) (free registration required)
• The SEC Office of the Inspector General issued a report on recommendations for improvements in the Division of Corporation Finance’s disclosure review program (August 26, 2025)
• The PCAOB announced the formation of the Smaller Firm Resource Group, an advisory group of professionals from smaller audit firms (August 26, 2025)
• The SEC Division of Corporation Finance released a new CDI providing guidance on when an issuer may become an accelerated or large accelerated filer after it loses its status as a smaller reporting company (August 27, 2025)
• The SEC published an update to its Financial Reporting Manual (August 28, 2025)
• The PCAOB announced that it postponed the effective date of its recently adopted quality control and ethics standards (August 28, 2025)
• KPMG published the results of its survey of audit committee members (August 31, 2025)
• CARB published a checklist for climate related financial risk disclosures (September 2, 2025)
• Nasdaq proposed changes to its initial and continued listing standards (September 3, 2025)
• The SEC released its Spring 2025 regulatory agenda (September 4, 2025)
• Nasdaq proposed a rule change to allow for the trading and settlement of tokenized securities (September 8, 2025)
• The SEC named James Moloney as the Director of the Division of Corporation Finance (September 10, 2025)
• The House Financial Services Committee conducted a hearing on proxy power and proposal abuse: reforming Rule 14a-8 to protect shareholder value (September 10, 2025)
• DFIN published its annual guide to effective proxies (September 10, 2025)
• Compensation Advisory Partners published an analysis of director compensation (September 10, 2025)
• The SEC issued a no-action letter approving a retail voting program (September 15, 2025)
• The SEC issued a policy statement addressing accelerating the effective date of registration statements for companies with mandatory arbitration provisions (September 17, 2025)
• Exxon filed the solicitation materials for its retail voting program (September 17, 2025)
• ISS published the results from its annual global benchmark policy survey (September 22, 2025)
• Ideagen published a 20-year study of audit fees (September 22, 2025) (free registration required)
• The SEC issued a statement on simultaneous commission consideration of settlement offers and related waiver requests (September 26, 2025)
• The SEC’s Office of Inspector General issued a report the SEC’s rulemaking process (September 29, 2025)
• The SEC Division of Corporation Finance updated its guidance for Division activities during a government shutdown (September 30, 2025)
• The SEC received a petition for rulemaking to amend quarterly reporting requirements under the Securities Exchange Act of 1934 (September 30, 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.