On December 18, 2025, President Trump signed the Fiscal Year 2026 National Defense Authorization Act (NDAA), which includes Section 8103—the “Holding Foreign Insiders Accountable Act.” This legislation alters the compliance landscape for foreign private issuers (FPIs) listed in the United States by imposing insider reporting obligations under Section 16(a) of
Continue Reading Foreign Private Issuer Insiders to Be Subject to Section 16(a) ReportingSEC Solicits Public Input on Definition of Foreign Private Issuer
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On June 4, 2025, the U.S. Securities and Exchange Commission announced that it published a concept release to solicit public comment on the definition of foreign private issuer (FPI). FPIs benefit from a number of accommodations from the reporting and disclosure requirements applicable to domestic issuers, such as registration and reporting forms designed for FPIs, longer timelines to file annual reports, no requirement to file quarterly reports, an exemption from the proxy rules, and the ability to present financial statements prepared in accordance with International Financial Reporting Standards, and insiders are exempt from obligations to file Section 16 ownership reports and are not subject to the short swing profit rule under the Securities Exchange Act of 1934 (Exchange Act).Continue Reading SEC Solicits Public Input on Definition of Foreign Private Issuer