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See FAQs, No. 7 (“Most solicitations/contracts that include CDI will also include non-CDI Federal contract information … it is likely that non-CDI Federal contract information will be flowed down to a subcontractor even when CDI is not, and as such, the FAR clause will flow down”). [read post]
27 Jul 2017, 4:32 pm by John Chierichella and Townsend Bourne
See FAQs, No. 7 (“Most solicitations/contracts that include CDI will also include non-CDI Federal contract information … it is likely that non-CDI Federal contract information will be flowed down to a subcontractor even when CDI is not, and as such, the FAR clause will flow down”). [read post]
3 Jul 2023, 6:23 pm by Jacob Katz Cogan
Contents include:Estudios sobre Ucrania Romualdo Bermejo-García, La crisis ucraniana: algo más que un conflicto entre Rusia y Ucrania Cesáreo Gutiérrez-Espada, De la guerra en Ucrania María-Dolores Bollo-Arocena, Agresión rusa a Ucrania, Crímenes Internacionales y Corte Penal Internacional Otros estudios doctrinales/li> Jaume Ferrer-Lloret, Las «consecuencias particulares» de las violaciones graves de normas de «ius… [read post]
10 Aug 2015, 7:20 am by John Jascob
The Division concluded that the procedures described would create a “substantive, pre-existing relationship” between the capital firm and prospective investors such that the offering and sales on the firm’s website would not constitute general solicitation or general advertising within the meaning of Rule 502(c) of Regulation D.In a new, related Compliance and Disclosure Interpretations (CDI) (Question 256.23, August 6, 2015), the Commission has stated that while the use… [read post]
23 Dec 2009, 3:43 am by Broc Romanek
The New Rules: Corp Fin Issues CD&Is as Transitional Guidance Yesterday, Corp Fin issued five new Compliance and Disclosure Interpretations to deal with some of the transitional issues posed by the February 28th effective date of the new executive compensation and proxy disclosure enhancement rules adopted last week, thereby tackling the "big question" that I blogged about last week. [read post]
26 Jan 2015, 6:10 am by Vanessa Schoenthaler
CorpFin issued two new Compliance and Disclosure Interpretations (C&DIs) on Friday, one presents a somewhat niche scenario involving application of the resale limitations set forth Rule 905 of Regulation S, and the other, of more general utility, addresses the treatment of non-searchable graphics in EDGAR filings. [read post]
28 May 2008, 4:31 am
Now Available: May-June Issue of The Corporate Counsel We just put the finishing touches and mailed the May-June '08 issue of The Corporate Counsel, which includes analysis of: - More on Obtaining Staff Guidance - Amended Rule 144 â [read post]
5 Jan 2011, 3:25 am by Jacob Katz Cogan
Contents include:Jorge Viñuales, Michel Virally ou penser le phénomène juridiqueSantiago Villalpando, Le codificateur et le juge face à la responsabilité internationale de l’État : interaction entre la CDI et la CIJ dans la détermination des règles secondairesHélène Tigroudja, Les accords du 17 novembre 2008 établissant le cadre juridique de la présence américaine en Irak et de la… [read post]
5 Feb 2013, 3:20 am by Broc Romanek
This Staff acknowledgement is informal (ie. even more informal than the 7 CDIs issued in December; Staff guidance is considered "informal" since it's not blessed by the Commissioners) - but seems to be based on the fact that Congress didn't limit the broad "affiliate" definition of Exchange Act Rule 12b-2 when it passed this legislation. [read post]
27 Oct 2009, 4:16 am
Corp Fin Issues Oil & Gas CDIs Yesterday, Corp Fin issued several Compliance & Disclosure Interpretations related to the oil and gas rules. [read post]
3 May 2023, 4:00 am by David Lynn
The SEC Staff addressed this concern in Exchange Act Form 8-K CDIs Question 109.02, which provides that if, in connection with an exit activity, the company is terminating employees as part of a plan to exit an activity that is covered by ASC 420, then the company is not required to disclose the commitment to the plan on Form 8-K until it has informed affected employees. [read post]
11 Jul 2023, 9:30 pm by Liz Dunshee
I am keeping my fingers crossed for “Christmas in July” – CDIs! [read post]
1 Dec 2016, 3:58 am by Broc Romanek
Whew, otherwise it would be nearly impossible to get no-action letters & CDIs out the door. [read post]
10 Jun 2024, 9:20 pm by Meredith Ervine
 I think much of that concern was assuaged by the December guidance released by multiple agencies — the FBI’s Guidance to Victims of Cyber Incidents on SEC Reporting Requirements: Request a Delay, plus multiple CDIs from the SEC Staff, and a statement from Corp Fin Director Erik Gerding — which evidenced that necessary interagency channels of communication were being forged and processes being created for these delay provisions to work. [read post]