On 3 September 2026, the SEC published updated Corporate Finance Interpretations (CFIs) relating to Exchange Act Section 13(d), Section 13(g) including Schedules 13D and 13G.
The questions below have been included:
- Q 103.13 – The context of shareholder discussions with an issuer about voting and their effect on ‘influencing’ control of an issuer is relevant for any impact on eligibility to file a 13G Report.
- Q 103.14 – Shareholder discussions with a proxy solicitation will not, on its own disqualify the ability to file a 13G Report.
- Q 103.15 – No disqualification from the ability to file a 13G report where a shareholder seeks clarification from an issuer about its disclosures or public communications.
The updated CFIs can be found here.