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Foreign Private Issuers Reporting Requirements Corporate Governance

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

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

Latham & Watkins LLP on

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

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

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

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

Herbert Smith Freehills Kramer

US Securities and Exchange Commission “Concept Release” on the definition of “Foreign Private Issuer”: The revisions could have...

On June 4, 2025, the US Securities and Exchange Commission (SEC) issued a “Concept Release” that will be of significant interest to our “foreign private issuer” (“FPI”) clients, their shareholders, and our investment banking...more

Katten Muchin Rosenman LLP

SEC Seeks Feedback on "Foreign Private Issuer" Definition and Accommodations

On June 4, 2025, the Securities and Exchange Commission (SEC) issued a concept release, soliciting public comment on the definition of "foreign private issuer."...more

Cooley LLP

The SEC’s Concept Release on the ‘Foreign Private Issuer’ Definition: Why It Matters

Cooley LLP on

Last week, the SEC issued this 71-page concept release to rethink the definition of “foreign private issuer” and determine which companies should get the benefits of reporting under the FPI reporting framework. Here’s the...more

BCLP

SEC Considers Modification of Foreign Private Issuer Criteria: May Result in Fewer Foreign Companies Qualifying as FPIs

BCLP on

On June 4, 2025, the SEC released a Concept Release seeking public comment on potential changes to the definition of foreign private issuer (“FPI”), which changes may have the effect of reducing the number of foreign...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Requests Public Comment on the Definition of Foreign Private Issuer

On June 4, 2025, the Securities and Exchange Commission (SEC) issued a concept release soliciting public input on whether the definition of foreign private issuer (FPI) should be amended, particularly given the significant...more

BCLP

New SEC Guidance Eases Form S-3 Registration Process for More Public Companies

BCLP on

The new registration statement guidance will make capital raises by non-WKSI companies filing on Form S-3 easier, as they can proceed with offerings during periods before their proxy statements are finalized – a privilege...more

White & Case LLP

Key Considerations for the 2025 Annual Reporting Season: Your Upcoming Form 20-F and other FPI-Specific Considerations

White & Case LLP on

With the inauguration of US President Trump on January 20, 2025, public companies await the impact of the new administration on the US Securities and Exchange Commission ("SEC"). President Trump's pick for the next SEC Chair,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Form 20-F for Fiscal Year 2024: What Foreign Private Issuers Should Keep in Mind

There have been a number of notable recent developments in SEC regulation of foreign private issuers (FPIs), including disclosure trends and rule changes that impact the annual report on Form 20-F for fiscal year 2024. In...more

White & Case LLP

Foreign Private Issuers: Don’t Forget to Confirm Your FPI Status!

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As we enter the second half of the year, it is once again time for many foreign private issuers (“FPIs”) to complete their annual assessment of FPI status. The determination of whether an issuer is an FPI must be made as of...more

Stikeman Elliott LLP

SEC Adopts New Cybersecurity Disclosure Rules for U.S. Public Companies and Foreign Private Issuers

Stikeman Elliott LLP on

The Securities and Exchange Commission (“SEC”) adopted new rules requiring the disclosure of cybersecurity risk management, strategy, governance and material incidents (the “Rules”), effective September 5, 2023. The Rules...more

Latham & Watkins LLP

SEC Adopts Cybersecurity Disclosure Rules

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The SEC, by a 3-2 vote, has adopted new rules requiring companies to provide: ..current disclosure on Form 8-K within four business days of determining that a material cybersecurity incident has occurred; and ...more

Dorsey & Whitney LLP

OTCQX International Rule Changes Will Push Certain Canadian Companies to the OTCQB Tier

Dorsey & Whitney LLP on

The OTC Markets has published proposed rule changes that would, effective September 23, 2021, require that in order to be quoted on the OTCQX International, a company must either be an SEC reporting company, file reports with...more

WilmerHale

SEC Amends Rule 15c2-11 to Enhance Publicly Available Information For Securities Quoted in the Over the Counter Markets

WilmerHale on

The Securities and Exchange Commission (SEC) has amended Rule 15c2-11 (the amended Rule), which governs the publication of quotations in the over-the-counter (OTC) markets, i.e., quotes that are published away from a...more

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