The Securities and Exchange Commission (SEC) has extended the deadline for issuers and obligors to self-report potential violations of their continuing disclosure obligations from the original deadline of September 10, 2014 to December 1, 2014. The text of the SEC press release may be viewed here.

The deadline for underwriters remains unchanged at September 10, 2014. For underwriters, the SEC has also implemented a tiered approach to civil penalties based on the size of the firm. The new tiered approach is:

  • For underwriters with 2013 reported total annual revenue of more than $100 million: $500,000
     
  • For underwriters with 2013 reported total annual revenue between $20 million and $100 million: $250,000
     
  • For underwriters with 2013 reported total annual revenue of less than $20 million: $100,000

 

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SEC

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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