JMM Articles

Corporate The SEC’s Three-Part Proposal in Support of Capital Formation: A Comprehensive Assessment of Combined Market Implications

Overview Over the past month, the SEC has launched a series of interconnected rulemaking initiatives that collectively redefine the regulatory architecture for domestic public companies. The package includes a May 5, 2026 proposed semiannual reporting rule (Release No. 33-11414) and two May 19, 2026 registered offering proposals: Enhancement of Emerging Growth Company Accommodations and Simplification […]

Corporate and Securities SEC Proposes Transformative Capital Markets Reforms: Simplifying Filer Tiers and Expanding Registered Offering Access

Overview On May 19, 2026, the Securities and Exchange Commission issued two companion proposing releases designed to constitute a coordinated capital formation package: (i) Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies (Release No. 33-11419), and (ii) Registered Offering Reform (Release No. 33-11418). Taken together, these proposals represent the […]

Taxation California’s Proposed Billionaire Tax: What High Net‑Worth Individuals Need to Know

California voters may soon be asked to decide on The Billionaire Tax Act, commonly referred to as the “Billionaire Tax.” Now that the measure achieved the signatures required to qualify for the ballot on November 3, 2026, the measure could have a meaningful impact on certain high net‑worth California residents. Below is a practical overview […]

Corporate SEC Proposes Semiannual Reporting Option: What Public Companies Need to Know About Semiannual Reporting

On May 5, 2026, the Securities and Exchange Commission (the “SEC”) issued a 279-page proposed rule that would allow eligible domestic reporting companies to replace quarterly Form 10-Q filings with a single semiannual report on new Form 10-S (Release No. 33-11414; the “Proposing Release”). If adopted, the proposed Form 10-S election would allow domestic issuers […]

Litigation ARL/CLRA Demand Letters Against Subscription-Based Businesses: How to Respond

Plaintiffs have been sending demand letters and filing lawsuits alleging violations of California’s Automatic Renewal Law (ARL), Cal. Bus. & Prof. Code §§ 17600 et seq., and the Consumers Legal Remedies Act (CLRA), Cal. Civ. Code §§ 1750 et seq. These demands focus on online checkout flows for recurring subscriptions where the company allegedly fails […]

Litigation Vivek Shah CIPA Demand Letters Against Business Websites: How to Respond

Vivek Shah, a serial pro se litigant, has been sending pre-litigation demand letters and filing lawsuits against businesses across the country alleging violations of California’s Invasion of Privacy Act (CIPA), Cal. Penal Code § 631(a). These demands focus on website search bars or forms that allegedly transmit user-entered content (such as a name typed into […]

Labor & Employment Deadline Approaching: California Employers Must Implement Emergency Contact Notification Policy by March 30, 2026

Significant monetary penalties may apply By Monday, March 30, 2026, employers must give employees the opportunity to name an emergency contact and to indicate whether that contact should be notified if the employee is arrested or detained at the worksite, during work hours, or while engaged in job duties offsite where the employer has actual […]

California’s Automatic Renewal Laws: How to Defend A Growing Wave of Class Action Lawsuits Targeting Subscription-Based Businesses

California businesses offering subscription services, from skincare products to online memberships, are increasingly finding themselves in the crosshairs of class action lawsuits alleging violations of the state’s Automatic Renewal Law (ARL). Enacted in 2010 and codified in California Business & Professions Code §§ 17600-17606, the ARL was designed to protect consumers from unauthorized recurring charges […]

Real Estate New FinCEN Reporting Rules Effective March 1, 2026

The Financial Crimes Enforcement Network (FinCEN) adopted a new residential real estate rule that will have a direct impact on purchasers of homes in the United States. Starting March 1, 2026, FinCEN’s new residential real estate rule will require certain individuals involved in real estate closings and settlements to file reports with FinCEN. These reports, […]

Bankruptcy California Court of Appeal Confirms Quasi-Judicial Immunity for Receivers

A new court decision confirms that receivers cannot be sued for decisions made in the exercise of their judgment, even if those decisions later prove to be wrong. In Semaan v. Mosier, G064385, (Cal. Ct. App. Feb. 5, 2026), a California case of first impression, the Court of Appeal held that court-appointed receivers in California are […]