Yesterday, Corp Fin posted a set of five FAQs related to the Section 16 obligations that commence on March 18th for insiders of foreign private issuers (those that aren’t exempt). The FAQs deal with the issues of:
- The need to file electronically on Edgar.
- Form 3s are due on March 18th (unless the person is no longer a Section 16 insider).
- Form 3s are due for people that become Section 16 insiders after December 31st but before March 18th (unless they became insiders since March 8th).
- Foreign private issuer registers equity securities for the first time between December 18th and March 18th – the insider owes a Form 3 on March 18th unless they became an insider since March 8th.
- If a foreign private issuer had equity securities registered prior to March 18th, then Rule 16a-2(a) would not obligate insiders to report on the first required Form 4 certain transactions effected prior to March 18th.
However, if the insider becomes subject to Section 16 because the foreign private issuer registers equity securities on or after March 18th, then Rule 16-2(a) would obligate such insider to report on the first required Form 4 certain transactions effected prior to March 18th.
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