July 21, 2012
Tracy Romano and Diane Frankle Author PLC Practice Note on Disclosure Implications for “Officers,” “Executive Officers” and “Named Executive Officers” under SEC Rules
New York Corporate Associate Tracy A. Romano and Palo Alto Corporate Partner Diane Holt Frankle authored the Practice Note “What’s in a Name? Disclosure Implications for ‘Officers,’ ‘Executive Officers’ and ‘Named Executive Officers’ under SEC Rules” for Practical Law Company. The Practice Note examines the definition of "officer" for purposes of Section 16 of the Exchange Act and the definitions of "executive officer" and "named executive officer" under Items 401 and 402 of Regulation S-K and the related Securities Act and the Exchange Act disclosure obligations. This Note also discusses Form 8-K reporting requirements for events involving certain officers.