Yesterday, Corp Fin revised its confidential submission processes for foreign private issuers so that they are treated like emerging growth companies for filing drafts, etc. This is good news as the same procedure for all types of drafts should makes it easier for us to remember. This process change is effective on a going-forward basis.
Here is the new paragraph added to Corp Fin’s processes:
In addition, foreign private issuers, whether submitting draft registration statements pursuant to this foreign issuer non-public submission policy or as an emerging growth company under the JOBS Act, will be required, at the time they publicly file their registration statements, to also publicly file their previously submitted draft registration statements and resubmit all previously submitted response letters to staff comments as correspondence on EDGAR. All staff comment letters and issuer response letters will be posted on EDGAR in accordance with staff policy. For foreign private issuers making non-public submissions pursuant to this policy, and not pursuant to the procedures available to emerging growth companies, this requirement will only apply to registration statements where the initial draft submission is made after May 30, 2012.
Our New “Board Meeting/Board Committee Disclosure Handbook”
Spanking brand new. Posted in our “Board Meetings” Practice Area, this comprehensive “Board Meeting/Board Committee Disclosure Handbook” provides a heap of practical guidance about the disclosure obligations under Item 407(b) of Regulation S-K.
More on “The Mentor Blog”
We continue to post new items daily on our blog – “The Mentor Blog” – for TheCorporateCounsel.net members. Members can sign up to get that blog pushed out to them via email whenever there is a new entry by simply inputting their email address on the left side of that blog. Here are some of the latest entries:
– Survey: Cybersecurity Risks Foremost on Auditor’s Mind
– Do You Have The Correct Authorized Number Of Directors?
– And Even More Board Trends…
– ‘Do I need to quit my job?’
– And More Board Trends…
– Notes from PLI’s “SEC Speaks” Conference
Deal Cube Tournament: Round One; 6th Match
As noted in these rules (and keep sending more pics for the next tourney), please vote for two of the following four cubes below:
– Broc Romanek