Our recent Client Alert discusses the exemptive order issued by the SEC on March 5, 2026, exempting directors and officers of certain foreign private issuers (FPIs) from Section 16(a) filing requirements. Subject to specified conditions, the order identifies Canada, Chile, the European Economic Area, the Republic of Korea, Switzerland, and the UK as qualifying jurisdictions and exempts directors and officers from the filing requirement if they report their transactions under identified qualifying regulations. Our Client Alert also discusses the Frequently Asked Questions published on March 9, 2026, by the staff of the SEC’s Division of Corporation Finance, relating to the new filing requirements. The FAQs confirm that Section 16(a) filings must be made via EDGAR (subject only to obtaining a hardship exception under Regulation S-T Rule 202) and clarified the due dates for the initial Form 3 filings, among other things.