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Disclosure Requirements Real Estate Investment Trust

A&O Shearman

A bold shot in the arm for Singapores Equities Markets

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The Equities Market Review Group has issued its first set of measures to strengthen the competitiveness of Singapore’s equities markets. The measures seek to (1) increase investor demand and the supply of quality listings on...more

Walkers

The Benefits of Guernsey and Jersey companies for UK and US listings

Walkers on

There is a growing trend for large UK-based companies to consider exploring listings on US stock exchanges such as the New York Stock Exchange (NYSE) and NASDAQ, potentially at the expense of the London Stock Exchange plc...more

Holland & Knight LLP

Significant Changes to SNF Disclosure Requirements Prompt Need for Regulatory Review

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To enhance quality of operations and increase transparency in ownership within skilled nursing facilities (SNFs), the Centers for Medicare & Medicaid Services (CMS) issued its Final Rule for ownership disclosures for Medicare...more

Mintz - Health Care Viewpoints

Off-Cycle Nursing Facility Revalidations Are Starting: Is Your SNF Ready for the Required Disclosures?

Commencing October 2024, CMS will start off-cycle revalidations of all Skilled Nursing Facilities (SNFs). As part of the revalidation process, SNFs must disclose the additional information required under CMS’ final rule,...more

Mayer Brown Free Writings + Perspectives

SEC Director Focuses on CRE Disclosures

As part of a panel discussion at the Practising Law Institute’s 2024 SEC Speaks Conference held on April 2, 2024, the Director of the SEC’s Division of Corporation Finance, Erik Gerding, highlighted several risks and...more

Akin Gump Strauss Hauer & Feld LLP

The Corporate Crimes Against Health Care Act: Washington Continues Efforts to Chill Private Equity Investment in Health Care

Senators Ed Markey (D-MA.) and Elizabeth Warren (D-MA.) unveiled “The Corporate Crimes Against Health Care Act of 2024” on June 11, 2024, which seeks to create new civil and criminal penalties for health care investors who...more

Morrison & Foerster LLP

A Comparative Analysis of 2022 and 2023 SEC Comments Issued to REITs

In recent years, the Securities and Exchange Commission (SEC) has increased its scrutiny of disclosure in public filings, as evidenced by an increase in the number of comments issued to public reporting companies. This trend...more

Davis Wright Tremaine LLP

Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

McCarter & English, LLP

Next Stop, Revalidation Station: CMS Final Rule for Nursing Home Transparency to Prompt Off-Cycle Revalidation, Revised Form...

Nursing facilities should prepare to provide the Centers for Medicare & Medicaid Services (CMS) with additional information about their ownership, their managing employees and the parties providing certain financial and...more

Goodwin

Additional Disclosure Required: CMS Implements Substantial Changes to Reporting Skilled Nursing Facility Ownership Information

Goodwin on

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule that will require skilled nursing facilities (SNFs) to disclose an expanded array of ownership, managerial, and control information...more

Morrison & Foerster LLP

MoFoREAL: European Real Estate Newsletter (Q3 2023)

Welcome to the latest edition of MoFoReal, our newsletter highlighting recent activities of and other developments in MoFo’s European Real Estate team. In this edition, we consider the Sustainability Disclosure Regulations...more

Goodwin

Blind Pool REIT IPOs: Real Estate Sponsors Are Getting Ready To Jump Back In

Goodwin on

Coming out of the Great Recession, there was a rush by real estate sponsors to raise “blind pool” capital to take advantage of displacement and distress in the real estate market. From 2009 through 2010, 30 new public real...more

Troutman Pepper Locke

New Disclosure Requirements for Public REITs' Share Repurchases

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On May 3, the Securities and Exchange Commission (SEC) adopted final amendments that call for certain quantitative and qualitative disclosure requirements with respect to repurchases of an issuer’s equity securities that are...more

Vinson & Elkins LLP

REITs To Be Impacted By New SEC Share Repurchase Disclosure Requirements

Vinson & Elkins LLP on

Public REITs should take steps to enhance their financial reporting processes to ensure that they will be able to provide daily quantitative share repurchase information and comply with additional new disclosure requirements...more

McDermott Will & Emery

Biden Administration and CMS Propose New Rule to Provide Greater Transparency for Nursing Home Ownership

McDermott Will & Emery on

Following the Biden administration’s efforts to promote nursing home safety, transparency, accountability and quality, the US Centers for Medicare & Medicaid Services (CMS) announced a proposed rule governing nursing home...more

ArentFox Schiff

Proposed Nursing Home Disclosure Requirements Target Private Equity Companies and REITs

ArentFox Schiff on

On February 15, 2023, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule which would require greater disclosures of the ownership and management of Medicare and Medicaid nursing homes. Specifically,...more

Sheppard Mullin Richter & Hampton LLP

CMS Issues Proposed Rule Requiring Nursing Homes to Disclose Additional Ownership Information, Including Ties to Private Equity...

On February 15, 2023, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that would require nursing homes enrolled in Medicare and Medicaid to disclose new information about their ownership and...more

Mintz - Health Care Viewpoints

CMS Proposes New Disclosure of Ownership Regulations for Nursing Facilities - Top Five Takeaways for Private Equity Firms and...

Private equity (PE) ownership of health care providers is unquestionably under scrutiny by federal and state regulators. States are passing laws that either directly or indirectly target PE health care transactions. For...more

Goodwin

Goodwin REIT Alert: REIT Disclosure Requirements When Acquiring or Disposing of Real Estate Operations

Goodwin on

When a public REIT acquires or disposes of real estate, the transaction may trigger financial disclosure requirements under SEC rules and guidance. Specifically, Rule 3-14 of Regulation S-X (“Rule 3-14”) sets forth the...more

Dorsey & Whitney LLP

REIT Alert: SEC Updates Financial Disclosures about Acquisitions and Dispositions of Businesses, Including Real Estate Operations

Dorsey & Whitney LLP on

Earlier this year, the Securities and Exchange Commission updated its requirements to provide financial information about acquisitions and dispositions of businesses and real estate operations, the first time that these...more

Morgan Lewis

CFTC Subcommittee Issues ‘First of Its Kind’ Climate Risk Report

Morgan Lewis on

A recent report from the US Commodity Futures Trading Commission encourages financial regulators to consider the risks climate change poses to the US financial system and includes recommendations for addressing these risks....more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Shaw LLP on

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Proskauer Rose LLP

The SEC's New Disclosure Regime for Real Estate Acquisitions - A User's Guide for REITs

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The Securities and Exchange Commission (the "SEC") recently adopted amendments to Regulation S-X and related rules and forms that will streamline and reduce the financial statements required to be filed in connection with...more

King & Spalding

REIT Advisor – March 2020 pt 2

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The rapidly developing news on the spread of the Coronavirus Disease 2019 (“COVID-19”) in the United States and other nations across the world has resulted in significant turmoil in global financial markets, bringing renewed...more

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