Washington, DC:
1625 Eye Street, NW
Washington, DC 20006
Phone+1-202-383-5107
Fax+1-202-383-5414

 

Rebekah Toton

Counsel


Rebekah Toton is a counsel in O’Melveny's Washington, DC office and a member of the Capital Markets Practice.  Rebekah’s practice focuses on assisting public companies with securities law issues, including SEC reporting and disclosure requirements, corporate governance matters, and compliance with exchange listing standards and the Sarbanes-Oxley Act.

Before coming to O’Melveny, Rebekah was a staff attorney in the Division of Corporation Finance of the US Securities and Exchange Commission. Rebekah served at the SEC from 2003 to 2007 in the Office of Computers and Online Services and was an examiner and reviewer on the Division’s Shareholder Proposal Taskforce in the Office of Chief Counsel. As a staff attorney, she screened Securities Act and Exchange Act filings to identify legal and accounting issues to determine the level of SEC staff review and reviewed Securities Act and Exchange Act filings for compliance with the federal securities laws. These Securities Act filings often involved initial public offerings, mergers and acquisitions, spin-offs, exchange offers, tender offers, debt offerings, equity lines and PIPEs. The reviews of Exchange Act filings included periodic reports, proxy material, tender offer documents, proxy contests and going-private transactions.

Professional Activities

Member, American Bar Association; Texas Bar Association


University of North Carolina at Chapel Hill, J.D.

Southern Methodist University, B.A., Political Science, Public Policy and International Studies; B.S., Economics with Financial Applications

London School of Economics and Political Science, London, England, General Course Studies (no degree awarded)


District of Columbia

Texas



SEC’s Division of Corporation Finance Publishes Guidance Regarding Shareholder Proposals (Capital Markets)

SEC Proposes Revisions to Regulation D and Rule 144A Allowing for General Solicitation And General Advertisement (Capital Markets)

Swap Product Definitions Finalized: Compliance Dates Set (Financial Services)

SEC Adopts Compensation Committees and Compensation Adviser Rules (Public Company Advisory Group)

SEC Staff Publishes FAQs on the JOBS Act “IPO On-Ramp” (Public Company Advisory Group)

FAQs on JOBS Act Amendments to Exchange Act Registration Thresholds (Public Company Advisory Group)

SEC Staff Publishes FAQs on JOBS Act Implementation (Public Company Advisory Group)

Guidance Regarding Rule 506 Offerings Prior to the SEC Adopting Rules Implementing the JOBS Act (Public Company Advisory Group)

SEC Staff Announces Process for Confidential Review of Registration Statements under the JOBS Act (Public Company Advisory Group)

JOBS Act Approved by the US Congress (Public Company Advisory Group)

SEC Responds to No-Action Requests Regarding Proxy Access Proposals (Financial Services)

NYSE Limits Broker Voting on Corporate Governance Proposals (Corporate Finance / Capital Markets)

Proxy Access to Proceed Through Shareholder Proposals (Corporate Finance / Capital Markets)

Proxy Access Rule Vacated (Corporate Finance / Capital Markets)

SEC's Recent Corporation Finance Statements (Corporate Finance / Capital Markets)

SEC Votes to Propose A New Rule and Rule Amendments Regarding Compensation Committee Structure and Disclosure(Corporate Finance / Capital Markets)

SEC Seeks Public Comment on Reform of the U.S. Proxy System (Corporate Finance Alert)

SEC Adopts Interpretive Guidance on Climate Change Disclosure (Corporate Finance Alert)

SEC Approves Significant New Proxy Disclosure Requirements (Corporate Finance Alert)

SEC’s Division of Corporation Finance Publishes Guidance Regarding Shareholder Proposals (Corporate Finance Alert)

Securities and Exchange Commission Announces Changes to Short Selling Rules (Corporate Finance Alert)

SEC Proposes Significant Proxy Rule Amendments (Corporate Finance Alert)

SEC Proposes "Proxy Access" Rules (Corporate Finance Alert)

SEC Issues Updated Guidance on Rule 10b5-1 Trading Plans (Corporate Finance Alert)

Proposed Delaware General Corporation Law Amendments (Corporate Finance Alert)

O'Melveny & Myers Client Alaska Air Group Receives Groundbreaking Shareholder Proposal No-Action Letter (Corporate Finance Alert)

The Delaware Supreme Court Rules in CA, Inc. v. AFSCME: A New Framework for Analyzing Bylaws and Shareholder Proposals (Corporate Finance Alert)

SEC Votes to Provide New Interpretive Guidance Regarding Corporate Websites (Corporate Finance Alert)

Securities and Exchange Commission Issues New Rules on Short Selling (Corporate Finance Alert)

Securities and Exchange Commission Extends Effective Dates of Emergency Actions Regarding Short Sales and Issuer Repurchases (Corporate Finance Alert)

SEC Amends the Rule 12g3-2(b) Exemption for Foreign Private Issuers (Corporate Finance Alert)

How to Comply with the SEC Short Sale Disclosure Requirement (Corporate Finance Alert)

The SEC Staff Provides Guidance Regarding Shareholder Proposals (Corporate Finance Alert)