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Orrick, Herrington & Sutcliffe LLP

SEC Considers Revising Foreign Private Issuer Definition

The Securities and Exchange Commission (SEC) issued a concept release seeking public comment by September 8, 2025, on its definition of “foreign private issuer” (FPI). The SEC indicated that a review is warranted due to...more

BCLP

SEC Considers Modification of Foreign Private Issuer Criteria: May Result in Fewer Foreign Companies Qualifying as FPIs

BCLP on

On June 4, 2025, the SEC released a Concept Release seeking public comment on potential changes to the definition of foreign private issuer (“FPI”), which changes may have the effect of reducing the number of foreign...more

Hone Maxwell

BE-10 Survey: What You Need To Know

Hone Maxwell on

The BE-10 is a mandatory survey conducted by the Department of Commerce’s Bureau of Economic Analysis (BEA) every 5 years. Its purpose is to gather information on U.S. direct investments abroad, including financial and...more

Lerman Senter PLLC

FCC Proposes Broad Foreign Ownership Certification and Reporting Requirements

Lerman Senter PLLC on

The Federal Communications Commission has released a Notice of Proposed Rulemaking (NPRM) proposing expansive new certification and disclosure requirements regarding foreign adversary ownership or control. The proposed...more

Akerman LLP

BE-10 Benchmark Survey of U.S. Direct Investment Abroad Due May 30

Akerman LLP on

The Bureau of Economic Analysis (BEA) of the U.S. Department of Commerce is currently conducting its BE-10 Benchmark Survey of U.S. Direct Investment Abroad, which is due May 30, 2025. This survey stands as the most...more

DLA Piper

BE-10 Filing Required for US Companies with Ownership in Non-US Businesses: Due May 30, 2025

DLA Piper on

The US Department of Commerce’s Bureau of Economic Analysis (BEA) conducts a mandatory BE-10 survey of US investments abroad every five years to produce key economic and statistical reports on the scale and effects of...more

Holland & Knight LLP

Education Dept. Prioritizes Foreign Gifts and Contracts Enforcement for Colleges, Universities

Holland & Knight LLP on

The Trump Administration stated last week that it will prioritize compliance and enforcement against colleges and universities with respect to the U.S. Department of Education (ED)'s foreign gift, contract and ownership...more

Akin Gump Strauss Hauer & Feld LLP

Transparency Regarding Foreign Influence at American Universities (Trump EO Tracker)

The Order requires the Secretary of Education to take all appropriate actions to ensure complete and timely disclosure by higher education institutions of foreign funding. The Secretary will take appropriate steps to reverse...more

Skadden, Arps, Slate, Meagher & Flom LLP

2025 Annual Meeting Filing and Disclosure Reminders

When finalizing proxy materials for annual shareholder meetings, we recommend that companies consider the recent changes to proxy disclosure requirements and other disclosure trends summarized in our December 11, 2024, client...more

Patterson Belknap Webb & Tyler LLP

The Holding Foreign Companies Accountable Act and its Potential Repercussions

U.S. capital markets are beginning to experience the effects of the passage of the Holding Foreign Companies Accountable Act (HFCAA). Amid continuing tensions between the United States and China, then-President Trump signed...more

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