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In brief

The Securities and Exchange Commission (“Commission“) recently published a concept release soliciting public comment on a new definition of foreign private issuer (FPI). The release reviews the background and regulatory purposes behind the existing framework that provides FPIs with less comprehensive regulation by the SEC than domestic issuers. The release explains that these regulatory accommodations were based on the Commission’s understanding that FPIs were subject to “different circumstances than domestic issuers” that needed to be accounted for, such as requirements to comply with “laws and practices imposed by … home country jurisdictions.” Such home country laws included regulations imposed by foreign securities exchanges where the FPI’s securities are listed, and “meaningful disclosure and other regulatory requirements” existing in the FPI’s home country jurisdiction. The FPI accommodations were intended to minimize the US regulatory burden of FPIs listing in multiple jurisdictions and therefore provide US investors greater access to FPI securities while still maintaining appropriate investor protections.


However, a recent Commission study compared recent characteristics of reporting FPIs with the characteristics of FPIs from 20 years earlier and that study undercuts the premises upon which the FPI accommodations were formulated. In this study the Commission found that a shift in the nature of the FPI population has occurred in recent decades. This shift includes a dramatic increase in the number of “China based issuers” that are almost always incorporated in lightly regulated tax havens (e.g., Cayman Islands, British Virgin Islands, Bermuda etc.) lacking comprehensive home-country disclosure laws and practices. In addition, the study showed that the equity securities of many FPIs are traded primarily, if not solely, in the United States, which is contrary to the Commission’s expectations when the FPI rules were established.

Based on these and other trends, the Commission expressed concern that the current FPI definition may no longer be appropriately tailored to the purpose behind establishing an accommodating FPI framework and suggested potential amendments.

Click here to access the full alert.

Author

Roger Bivans is a seasoned lawyer focused on strategic transactions, including domestic and multinational mergers and acquisitions, carve-out and joint venture transactions, capital markets transactions, securities regulation and corporate governance matters and general commercial transactions. He is recognized by Chambers USA for Corporate/M&A. A frequent speaker on securities regulation, he is the current Dallas chapter president of the Society for Corporate Governance and moderator of the DFW Securities Law Discussion Group. Mr. Bivans previously served as a surface warfare officer in the United States Navy.

Author

Mark Mandel is Chair of the North America Capital Markets Practice Group, member of the Global Capital Markets Steering Committee and Co-Chair of the Transactional Practice Group in New York and Miami. Mr. Mandel has been named by Legal 500 as one of the leading lawyers in the US for mergers and acquisitions and recognized by IFLR 1000 for mergers and acquisitions and capital markets. Mark has also been designated a "stand-out lawyer" by Acritas Stars. Mark was named in Attorney Intel’s Top 25 M&A Attorneys of 2024.

Author

Thomas Rice is a member of the Firm's Transactional Practice Group in the New York office. He previously served as a member of the Firm's Global Capital Markets Steering Committee.
While in law school, Thomas served on the Moot Court Board from 1983 to 1984 and was a Moot Court Editor from 1984 to 1985.

Author

Carol B. Stubblefield is a member of the Firm’s North American Corporate & Securities Practice Group in the New York office. Ms. Stubblefield regularly represents public companies, issuers and underwriters in connection with public and private offerings of debt and equity securities. Ms. Stubblefield provides general corporate counseling and corporate governance advice. She advises companies on M&A transactions, including complex cross-border acquisitions and divestures. She also advises on pre and post transaction restructuring activities.
Carol regularly advises on pro bono matters and is active in the Firm's community service efforts.

Author

Adam Buehler is a senior associate in the Miami office of Baker McKenzie and a member of the North America Transactional Group. Adam represents clients in the areas of public and private offerings of debt and equity securities, public company securities law compliance, and global reorganization transactions.
Adam is also proficient in German.