A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets.
This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength.
Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations.
Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
Since the mid-1970s the SEC has required companies to acknowledge in writing that the disclosure in any filed documents was the responsibility of the filer...
Since the mid-1970s the SEC has required companies to
acknowledge in writing that the disclosure in any filed documents
was the responsibility of the filer and that the SEC review process
would not be raised as a defence in legal proceedings. The SEC has
required the same acknowledgement, known as the "Tandy"
language (after the first company to receive a comment letter
containing this language), in comment letters since they became
publicly available in 2004.
While companies remain responsible for the accuracy and adequacy
of their disclosure, going forward, the SEC will include the
following statement in comment letters, without requiring an
affirmative response in the form of the "Tandy"
representation from the reviewed filer:
"We remind you that the
company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review,
comments, action or absence of action by the staff."
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