SEC Updates C&DIs on Beneficial Ownership Reporting

The staff in the SEC’s Division of Corporation Finance (the “Division”) has updated its Compliance and Disclosure Interpretations (C&DIs) related to Exchange Act Sections 13(d) and 13(g) as well as Regulation 13D-G, which address beneficial ownership reporting. Specifically, the Division revised certain questions in Sections 101 (on general applicability), 103 (on filing of Schedules 13D and 13G), 104 (on filing of amendments to Schedules 13D and 13G), 105 (on determination of beneficial ownership), 107 (on acquisition of securities), and 110 (on Schedule 13D).