Cybersecurity in the investment management industry
On February 27, 2026, the Securities and Exchange Commission (the SEC) adopted final rules to enact the requirements of the Holding Foreign Insiders Accountable Act (HFIA Act). These final rules, which mark a significant...more
Knowing that the SEC’s EDGAR staff is facing a backlog to process a deluge of Form IDs – which will contribute to delinquencies in the early days for FPIs required to file their Form 3s on March 18th – Corp Fin added these...more
On March 12, 2026, the SEC staff issued two new FAQs related to the Holding Foreign Insiders Accountable Act (HFIA Act). The FAQs noted the HFIA Act requirements are resulting in an unusually large number of EDGAR access...more
The SEC has adopted a final rule implementing the Holding Foreign Insiders Accountable Act that, effective March 18, 2026, subjects directors and officers of foreign private issuers to the insider ownership reporting regime...more
Under the Holding Foreign Insiders Accountable Act (the “HFIAA”), signed into U.S. law on December 18, 2025, directors and officers of foreign private issuers with a class of equity securities registered on a U.S. national...more
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)....more
On March 5, 2026, the U.S. Securities and Exchange Commission ("SEC") issued an order (the "Exemptive Order") that provides a conditional exemption from the reporting requirements of Section 16(a) of the Securities Exchange...more
On March 9, 2026, the staff of the Division of Corporation Finance of the Securities and Exchange Commission published a short series of FAQs on the timing of initial Section 16(a) reports by directors and officers of certain...more
SEC final rule amendments require Section 16 beneficial ownership reporting by directors and officers of foreign private issuers. Key Takeaways Directors and officers of foreign private issuers (FPIs) are now subject to...more
Effective March 18, 2026, officers and directors of foreign private issuers that have securities listed on a U.S. securities exchange or registered with the Securities and Exchange Commission (SEC) (for purposes of this...more
In our prior client alert, we reported on the enactment of the Holding Foreign Insiders Accountable Act1 (HFIAA), which extends Section 16(a) insider reporting obligations under the Securities Exchange Act of 1934 (Exchange...more
Reminder: Effective March 18, 2026, directors and officers of foreign private issuers (“FPIs”) will become subject to reporting of their beneficial ownership and subsequent changes in beneficial ownership on Forms 3, 4, and 5...more
On February 27, 2026, the US Securities and Exchange Commission (“SEC”) adopted certain rule and form amendments implementing the landmark requirements of the Holding Foreign Insiders Accountable Act (“HIFAA”). ...more
On February 27, 2026, the Securities and Exchange Commission (SEC) issued final rules and form amendments to implement the Holding Foreign Insiders Accountable Act (HFIA Act)....more
On February 27, 2026, the U.S. Securities and Exchange Commission (SEC or Commission) announced that it adopted final rule and form amendments implementing the Holding Foreign Insiders Accountable Act (the HFIA Act). The HFIA...more
On December 18, 2025, President Trump signed into law the Holding Foreign Insiders Accountable Act (the “HFIAA”), which will terminate an exemption that long enabled directors and officers of foreign private issuers (“FPIs”)...more
Recent changes to U.S. securities law will significantly expand insider reporting obligations for directors and officers of Canadian companies that qualify as foreign private issuers (FPIs) with securities registered in the...more
On December 18, 2025, the Holding Foreign Insiders Accountable Act (the Act) was enacted as part of the 2026 National Defense Authorization Act. Effective March 18, 2026, the Act eliminates an exemption from the reporting...more
As you may recall, the Holding Foreign Insiders Accountable Act (the HFIAA) was signed into law on December 18, 2025. In a nutshell, this means that directors and officers of foreign private issuers whose securities are...more
On December 18, 2025, President Trump signed the 2026 National Defense Authorization Act, which includes the Holding Foreign Insiders Accountable Act (the HFIAA), expanding the scope of beneficial ownership reporting...more
On December 18, 2025, the Holding Foreign Insiders Accountable Act (“HFIAA”) was enacted as part of the FY 2026 National Defense Authorization Act. This new law amends Section 16(a) of the Securities Exchange Act of 1934, as...more
The Holding Foreign Insiders Accountable Act (HFIAA), which was signed into law on 18 December 2025, introduces a new compliance requirement for foreign private issuers (FPIs) that historically have not been subject to US...more
On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026. Section 8103 of the act, entitled the “Holding Foreign Insiders Accountable Act” (“HFIAA”), eliminates the...more
Starting on March 18, 2026, any executive officer or director of any “foreign private issuer”i (FPI) that has a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the...more