News & Analysis as of

Foreign Private Issuers

McGuireWoods LLP

McGuireWoods Quarterly Securities & Capital Markets Update - April 2026

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Welcome to the McGuireWoods Quarterly Securities & Capital Markets Update, a series of updates that reviews important securities law developments from the previous quarter and alerts readers of significant considerations for...more

Ropes & Gray LLP

SEC Aligns Its Rules with New Reporting Requirements for Directors and Officers of FPIs

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On February 27, 2026, the Securities and Exchange Commission (the SEC) adopted final rule and form amendments to reflect the requirements of the Holding Foreign Insiders Accountable Act (the HFIA Act), which was enacted on...more

Carey Olsen

Shareholder activism in Bermuda

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Shareholder activism has been on the rise globally over the past decade. Bermuda has not been immune from that trend. Shareholder activism in Bermuda often involves differing considerations unique to offshore jurisdictions....more

Fenwick & West LLP

Securities Law Update - March 2026

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Welcome to the latest edition of Fenwick’s Securities Law Update. This issue contains updates and important reminders on the following topics...more

Tarter Krinsky & Drogin LLP

Section 16(a) Reporting Obligations Now Apply to Directors and Officers of Foreign Private Issuers, Subject to Key SEC Exemptions

Effective March 18, 2026, directors and officers (“D&Os”) of foreign private issuers (“FPIs”) with a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the “Exchange...more

Bennett Jones LLP

Canadian Foreign Private Issuers Remain Exempt from US Insider Reporting Requirements

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"Foreign private issuers" under US securities laws have long been exempt from the insider reporting requirements of Section 16(a) of the US Securities Exchange Act of 1934, as amended (the Exchange Act). That looked set to...more

DLA Piper

SEC issues new and revised guidance related to Rule 701

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On March 6, 2026, the United States Securities and Exchange Commission (SEC) issued several new and revised Compliance and Disclosure Interpretations (C&DIs). Most of the C&DIs provide clarification on the requirements for...more

Goodwin

SEC Staff Issues Temporary Relief for Some Late Section 16(a) Reports

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The staff of the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) has published two FAQs that provide temporary, short-term, no-action relief for directors and officers of foreign...more

Cozen O'Connor

SEC Grants Targeted Section 16 Insider Reporting Relief for Canadian Foreign Private Issuers

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On March 5, 2026, the U.S. Securities and Exchange Commission issued an order providing targeted relief from Section 16 insider reporting obligations for directors and officers of foreign private issuers incorporated or...more

King & Spalding

New U.S. Insider Reporting Rules for Foreign Private Issuers: Who Must File, and Who Gets a Pass

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The U.S. Securities and Exchange Commission (the “SEC”) adopted final rules to implement the Holding Foreign Insiders Accountable Act (the “HFIAA”) on February 27, 2006, which take effect on March 18, 2026. The SEC then...more

White & Case LLP

SEC Staff Grants Temporary Section 16(a) Filing Relief To Directors And Officers Of Foreign Private Issuers Affected By Iran...

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On March 13, 2026, the Securities and Exchange Commission ("SEC") granted a no-action request giving directors and officers of foreign private issuers ("FPIs") organized and headquartered in Israel or any other country in the...more

Orrick, Herrington & Sutcliffe LLP

SEC Provides Relief for Section16(a) Reporting Deadlines Due to EDGAR Access Delays and Middle East Conflict

The reporting obligations for directors and officers of certain foreign private issuers (FPIs) are set to take effect starting on March 18, 2026. Recent developments from the Division of Corporation Finance, however, indicate...more

Venable LLP

SEC Grants Conditional Section 16(a) Relief for Certain FPIs

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On March 5, 2026, the Securities and Exchange Commission (SEC) issued an order granting conditional relief from Section 16(a) reporting requirements for directors and specified officers (Section 16 Officers) of certain...more

Ropes & Gray LLP

EDGAR Access Issues—and Iran Conflict—Trigger SEC Staff No-Action Relief for Section 16(a) Reports of Insiders of FPIs and...

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On March 12, 2026, the SEC staff granted no-action relief to directors, officers, and beneficial owners of domestic issuers, as well as directors and officers of foreign private issuers (FPIs) who are unable to timely file...more

Cooley LLP

Capital Markets Update - March 2026 One-Minute Reads

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On February 27, 2026, the Securities and Exchange Commission (SEC) announced the adoption of final rule and form amendments to reflect the requirements of the Holding Foreign Insiders Accountable (HFIA) Act....more

Haynes Boone

SEC Provides Certain Relief from Section 16(a) Reporting Obligations

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This alert highlights recent relief measures available to certain directors and officers of foreign private issuers (FPIs) subject to Section 16(a) reporting obligations under the Holding Foreign Insiders Accountable Act...more

Mayer Brown Free Writings + Perspectives

SEC Staff Grants Geographically-Based Section 16(a) Reporting No-Action Relief

On March 13, 2026, the Securities and Exchange Commission’s (the “SEC”) Division of Corporation Finance (the “Division”) stated in a no-action letter to an Israeli company that it would not recommend enforcement action to the...more

Mayer Brown Free Writings + Perspectives

Two More FAQs on the Holding Foreign Insiders Accountable Act

On March 12, 2026, the Securities and Exchange Commission’s Division of Corporation Finance (the “Division”) published two new FAQs on the application of the Holding Foreign Insiders Accountable Act to officers and directors...more

Cooley LLP

Section 16 for FPIs: Temporary No-Action Relief for Insiders in War-Torn Countries

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On Friday, Corp Fin granted global no-action relief to insiders of foreign private issuers in countries impacted directly by the war going on in Iran – so that the compliance deadline for those insiders is April 20th (rather...more

DLA Piper

SEC Provides Relief From Newly Imposed Section 16(a) Insider Reporting For FPIs

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On March 5, 2026, the United States Securities and Exchange Commission (SEC) issued an order (Order) granting an exemption from insider reporting requirements under Section 16(a) of the Securities Exchange Act of 1934...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Grants Extension for D&Os of Certain FPIs Directly Affected by Iran War to Comply With New Section 16(a) Insider Reporting...

On March 13, 2026, in response to a no-action request submitted by Skadden on behalf of a client, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued a no-action letter...more

A&O Shearman

SEC effectively extends deadline for late Section 16(a) filings caused by lack of EDGAR access

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As we explained in our recent article, under the Holding Foreign Insiders Accountable Act (HFIAA), directors and officers of foreign private issuers (FPIs) become subject to Section 16(a) reporting requirements on March 18,...more

Wilson Sonsini Goodrich & Rosati

SEC Gives Enforcement Relief to Section 16 Persons of Foreign Private Issuers in War-Affected Middle East

On Friday, March 13, 2026, the SEC staff granted no-action relief to directors and officers of any foreign private issuer with a class of equity securities registered under Exchange Act Section 12 that is organized and...more

Stikeman Elliott LLP

SEC Exempts D&Os of Canadian Issuers from Section 16(a) Insider Reporting

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On March 5, 2026, the U.S. Securities and Exchange Commission (“SEC”) issued an order (the “Order”) granting directors and officers of certain foreign private issuers (“FPIs”) an exemption from the insider reporting...more

Akin Gump Strauss Hauer & Feld LLP

SEC Adopts Final Rules Requiring Section 16(a) Reporting for Directors and Officers of FPIs, and Provides Exemptive Relief for FPI...

On February 27, 2026, the SEC adopted final amendments to its rules and forms under the Exchange Act to implement the HFIA Act. As we discussed in our December 2025 alert, the HFIA Act was enacted on December 18, 2025, as...more

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