News & Analysis as of

Foreign Private Issuers

Sheppard Mullin Richter & Hampton LLP

Nasdaq Proposes Significant Changes to Initial and Continued Listing Standards

On September 3, 2025, The Nasdaq Stock Market LLC (Nasdaq) announced proposed changes to its listing standards. According to Nasdaq, these proposed changes respond to the rising complexity and volatility in today’s capital...more

Saul Ewing LLP

Public Companies Quarterly Update (Q2 2025)

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Welcome to Saul Ewing's Public Companies Quarterly Update series. Our intent is to, on a quarterly basis, highlight important legal developments of which we think public companies should be aware....more

Paul Hastings LLP

SEC Commissioner Paul Atkins Promises Increased Enforcement of US-Listed Chinese Companies

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During Securities and Exchange Commission Chairman Paul Atkins’ Senate confirmation hearing, a lawmaker asked him, “Would [you] investigate Chinese companies for … wanton and blatant violations of U.S. disclosure laws that...more

Woodruff Sawyer

Will the SEC’s Changes to the Foreign Private Issuer Definition Affect SPACs?

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On June 4, the Securities and Exchange Commission (SEC) issued a concept release seeking public comment on the definition of the term "foreign private issuer" (FPI). The request is in response to global market changes and...more

Paul Hastings LLP

Public Company Watch: Q2 2025

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This edition of the Public Company Watch highlights critical updates and regulatory changes affecting public companies. Staying informed on these topics is crucial for effective compliance and strategic planning....more

Ropes & Gray LLP

Capital Markets & Governance Insights - July 2025

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In a broad reversal of course on proposed rules issued by the Securities and Exchange Commission (SEC) under the leadership of former SEC Chair Gary Gensler, on June 12, 2025, the SEC issued a notice withdrawing fourteen of...more

Proskauer Rose LLP

A Securities and Exchange Commission (SEC) Analisará os Critérios de Elegibilidade para Emissores Privados Estrangeiros (Foreign...

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Empresas latino-americanas com valores mobiliários registrados nos Estados Unidos, ou que pretendem registrá-los, devem ficar atentas. A SEC (Comissão de Valores Mobiliários dos EUA) publicou um “concept release” propondo...more

Hogan Lovells

Cross-border SEC spotlight: Key updates for non-U.S. companies – Q2 2025

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Welcome back to our Hogan Lovells Cross-border SEC spotlight: Key updates for non-U.S. companies, a dedicated resource for non-U.S. companies listed or exploring a listing in the United States. This newsletter is published...more

Davies Ward Phillips & Vineberg LLP

Concept Release: Foreign Private Issuers Under the SEC’s Microscope

Do the U.S. securities law accommodations through the “foreign private issuer” (FPI) construct benefit the intended entities? That’s the fundamental question that the U.S. Securities and Exchange Commission (SEC) is analyzing...more

Morgan Lewis

SEC Requests Public Comment on Changes to the Definition of ‘Foreign Private Issuer’

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On June 4, 2025, the US Securities and Exchange Commission published a concept release to solicit comments on whether and how the definition of “foreign private issuer” (FPI) should be changed. As a result of recent...more

Troutman Pepper Locke

Foreign Private Issuers: Have You Assessed Your Status Under US Securities Laws? (UPDATED)

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For foreign private issuers registered with the U.S. Securities and Exchange Commission (SEC), there are several filing statuses that affect the content of various disclosures that must be made public. Foreign private issuers...more

K&L Gates LLP

SEC Reassesses Foreign Private Issuer Eligibility

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Earlier this month, the US Securities and Exchange Commission (SEC) issued a concept release to solicit public comment on potential changes to the definition of a foreign private issuer (FPI), marking the SEC’s first review...more

Latham & Watkins LLP

Desktop Reference for Foreign Private Issuers With FYE 30 June 2025

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This Latham resource allows FPIs with a 30 June fiscal year-end to stay abreast of key SEC filing dates and financial staleness deadlines....more

ArentFox Schiff

SEC’s New Concept Release on Foreign Private Issuer Standards

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On June 4, the US Securities and Exchange Commission (SEC) published a concept release soliciting public comment on potential amendments to the definition of foreign private issuer (FPI) under US securities laws....more

DLA Piper

The Commission’s Analysis of Recent Developments in the FPI Population

DLA Piper on

As discussed in our prior blog posts, on June 4, 2025, the US Securities and Exchange Commission (Commission) published a concept release (Release) soliciting comments on whether to revise the definition of “foreign private...more

Troutman Pepper Locke

Time to Assess "Foreign Private Issuer" Status - 2025

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It is time to assess “foreign private issuer” status. Foreign public and private issuers enjoy the benefits of significant exemptions and exclusions from registration under U.S. federal securities laws based on whether they...more

Orrick, Herrington & Sutcliffe LLP

SEC Considers Revising Foreign Private Issuer Definition

The Securities and Exchange Commission (SEC) issued a concept release seeking public comment by September 8, 2025, on its definition of “foreign private issuer” (FPI). The SEC indicated that a review is warranted due to...more

Alston & Bird

SEC Considers Changes to Foreign Private Issuer Definition

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The Securities and Exchange Commission (SEC) is mulling over modifications to the definition of foreign private issuer (FPI). Our Securities Group examines how these potential changes could impact companies currently...more

DLA Piper

Current State of Play for Foreign Private Issuers

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As discussed in our prior blog post, the US Securities and Exchange Commission (Commission) recently issued a concept release (Release) aiming to gather input on whether the criteria for designation as a foreign private...more

Fenwick & West LLP

SEC News Roundup - June 2025

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Petition for Rulemaking with Respect to Cybersecurity Incident Disclosure - A group of financial services industry trade associations submitted a joint petition for rulemaking requesting that the SEC amend the...more

Stikeman Elliott LLP

SEC Considers Amendments to “Foreign Private Issuer” Definition

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The U.S. Securities and Exchange Commission (“SEC”) recently published a concept release (the “Concept Release”) in which it solicits comments on potential revisions to the “foreign private issuer” (“FPI”) definition. The SEC...more

Goodwin

SEC Issues Concept Release on the Definition of Foreign Private Issuer

Goodwin on

On June 4, 2025, the Securities and Exchange Commission (“SEC”) published a concept release (“Concept Release”) soliciting public comments on the definition of a foreign private issuer (“FPI”). FPIs are subject to disclosure...more

Latham & Watkins LLP

Desktop Reference for Foreign Private Issuers With FYE 31 March 2025

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This Latham resource allows FPIs with a 31 March fiscal year-end to stay abreast of key SEC filing dates and financial staleness deadlines....more

Foley Hoag LLP - Public Companies & the Law

SEC Issues Concept Release Soliciting Public Comment on Foreign Private Issuer Definition

On June 4, 2025, the SEC issued a concept release soliciting public comment on the definition of “foreign private issuer” (FPI) under U.S. securities laws. The SEC has identified potential changes to the definition that could...more

Troutman Pepper Locke

SEC Considers Changes to Definition of Foreign Private Issuer

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On June 4, 2025, the U.S. Securities and Exchange Commission (SEC) published a concept release soliciting public comment on the definition of a foreign private issuer (FPI) and whether changes are needed to reflect the...more

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