On March 10, 2022, the Securities and Exchange Commission issued proposed rule amendments titled “Modernization of Beneficial Ownership Reporting,” which govern beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934. In response to the request from the SEC for additional comments on the proposed rules, the Committee on Federal Regulation of Securities of the Section of Business Law of the American Bar Association submitted a comment letter on April 28, 2022, which provided the views of many of the leading securities practitioners on the proposed rulemaking. The comment letter drafting committee was co-chaired and led by Cooley lawyers Reid Hooper and Justin Kisner.
Please note: The comments expressed in the letter represent the views of the committee only, have not been approved by the ABA’s House of Delegates or Board of Governors, and do not represent the official position of the ABA. In addition, the comment letter does not represent the official position of the ABA’s Section of Business Law or the views of the organizations with which members of the drafting committee may be affiliated.
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