On March 13, 2026, the Securities and Exchange Commission’s (the “SEC”) Division of Corporation Finance (the “Division”) stated in a no-action letter to an Israeli company that it would not recommend enforcement action to the SEC if the directors and officers of the company requesting relief do not file the beneficial ownership reports required by
Exchange Act
SEC Issues Order Granting Directors and Officers of Certain Foreign Private Issuers an Exemption from Section 16(a) Filing Requirements
On March 5, 2026, the Securities and Exchange Commission (the “SEC”) published an order granting an exemption from beneficial ownership reporting requirements under Section 16(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) for officers and directors of certain foreign private issuers (“FPIs”). As we previously reported here, on February 27, 2026…
Foreign Issuers and Section 16 Reporting: SEC Adopts Final Rules for the Holding Foreign Insiders Accountable Act
The Securities and Exchange Commission today adopted final rules and form amendments to reflect the requirements of the recently enacted Holding Foreign Insiders Accountable (“HFIA”) Act.
Directors and officers of foreign private issuers, or FPIs, with a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the…
SEC Signals Incoming Relief For De Minimis Security-Based Swap Dealers
On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap (“SBS”) dealing. While the relief will not be issued as long as the government shutdown persists, his statement…
New Exchange Act Rules Compliance and Disclosure Interpretation 130.05
On August 27, 2025, the staff of the Securities and Exchange Commission (the “SEC”) published new Exchange Act Rules Compliance and Disclosure Interpretation 130.05, governing the treatment of certain former smaller reporting companies (“SRCs”) under the federal securities laws in the fiscal year after such a former SRC ceases to qualify as an SRC.
By…
SEC Formally Withdraws Various Proposed Rules
- Conflicts of
SEC Expands Accommodations for Issuers Submitting Draft Registration Statements
- expand the availability of the SEC’s confidential review process for
SEC Drops Appeal of “Dealer Rule” Litigation
On February 19, 2025, the Securities and Exchange Commission (the “Commission” or “SEC”) dropped its appeal of a ruling by the U.S. District Court for the Northern District of Texas (“District Court”) on November 6, 2024 that struck down the Commission’s “Dealer Rule.”
The Dealer Rule, adopted by the SEC on February 6, 2024, further…
SEC Adopts Amendments Mandating Certain Exchange Act Filings and Submissions to be Made Electronically; Also Adopts Technical Changes Regarding FOCUS Reports
On December 16, 2024, the Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) requiring the electronic filing, submission, or posting of certain forms required under the Securities Exchange Act of 1934 and the rules and regulations thereunder, using structured, machine-readable data language as appropriate. The SEC also adopted amendments to the Financial and Operational…
Regulation M: the Basics, the Amendments and their Effect on Offerings
- An overview of Reg M, specifically, Rules 101 and 102
- An overview of the

