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2017

SEC Makes Nonpublic Review Process for Draft IPOs and Initial Registration Statements Available to All Companies (July 11, 2017)

Heads Up | Volume 24, Issue 17
August 24, 2017 (Originally Issued July 11, 2017)
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SEC Makes Nonpublic Review Process for Draft IPOs and Initial Registration Statements Available to All Companies

This Heads Up has been revised to reflect an update to the June 29, 2017, announcement (see discussion below) by the SEC’s Division of Corporation Finance (the “Division”). The update clarifies a company’s eligibility for benefits and discusses transition considerations under the expanded nonpublic review process.
The Heads Up has also been revised to discuss the Division’s issuance of two new compliance and disclosure interpretations (C&DIs) on Securities Act forms (Questions 101.04 and 101.05) and an updated C&DI on the Fixing America’s Surface Transportation (FAST) Act (Question 1). The C&DIs address questions related to omitting, from draft registration statements, interim and annual financial information that a company reasonably believes will not need to be presented separately at the time its registration statement is filed publicly or, for emerging growth companies (EGCs), at the time of the offering.

Footnotes