U.S. – SEC Re-Opens Comment Period on Proposed Changes to 13D/G Filing

U.S. – SEC Re-Opens Comment Period on Proposed Changes to 13D/G Filing

On 28 April 28, 2023, SEC reopened comment period to allow persons opportunity to comment on additional analysis, data contained in new staff memorandum published.

  • Memo provided additional background, baseline data on Schedule 13D and 13G filings.
  • Investigated effects on activism from proposed change to Schedule 13D filing deadline.
  • Additional analysis of harms to certain selling shareholders under existing deadline.
  • Discussion of relevant academic research as well as new quantitative analysis.
  • Comments due later of 30 days after publication in federal register or 27 June 2023.