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Comment Letter - SEC’s concept release on foreign private issuer eligibility


Overview

In our comment letter, we support the SEC’s decision to review the FPI definition and consider whether updates are appropriate given developments in the global markets since the definition was last updated. We highlight the importance that any new definition be operational and retain the FPI definition’s original intent to provide accommodations for issuers subject to meaningful non-US regulation and oversight. We also provide recommendations regarding transition to mitigate disruption, preserve investor protection and support continued access to US capital markets.

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