July 19, 2023
Guide to Determining Filer and SRC Status
With June 30th — a key date for calendar year-end public companies — just behind us, Cooley recently released a set of flowcharts to guide companies through “the statutory and regulatory requirements for entering and exiting non-accelerated, accelerated and large accelerated filer status, as well as smaller reporting company status.” This new resource starts by identifying information that users of the flowcharts should gather before working through them, including public float, annual revenue, and fiscal year information. It then addresses key questions through the following six flowcharts, which are color-coded for ease of use:
– Smaller Reporting Company – Initial Qualification and Annual Reevaluation for SRCs
– Smaller Reporting Company – Annual Reevaluation for Non-SRCs
– Non-Accelerated Filer – First Reevaluation for Non-Accelerated Filer After Becoming a Reporting Company
– Smaller Reporting Company and Non-Accelerated Filer – Annual Reevaluation for a Smaller Reporting Company and Non-Accelerated Filer
– Accelerated Filer – Annual Reevaluation
– Large Accelerated Filer – Annual Reevaluation
– Meredith Ervine
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