Planning for a Potential Government Shutdown

The U.S. government is heading for a shutdown on Wednesday, October 1, 2025, if Democratic and Republican congressional lawmakers fail to reach a funding deal before then. Back in March of this year, the SEC’s Division of Corporation Finance (the “Division”) released an announcement containing a series of FAQs on what SEC registrants can expect in the event of a government shutdown. In particular, the announcement notes that the Division’s operating status may be uncertain, its “activities will be extremely limited,” and it “will not be able to accelerate the effectiveness of registration statements.” Accordingly, the announcement points out that “registrants with pending registration or offering statements that are substantially complete, and that have met all statutory requirements to request acceleration of the effective date (including the dissemination of any draft registration statement for the required periods under Securities Act Section 6(e) or the related Division accommodations) or qualification, may want to consider requesting effectiveness or qualification while the Division continues its normal operations.”