SEC Gives Enforcement Relief to Section 16 Persons of Foreign Private Issuers—and Domestic Issuers—If They Are Unable to Timely File Because They Cannot Obtain EDGAR Codes in Time
On March 12, 2026, the SEC staff issued two new FAQs related to the Holding Foreign Insiders Accountable Act (HFIA Act). The FAQs noted the HFIA Act requirements are resulting in an unusually large number of EDGAR access applications, which suggests that the staff may be unable to provide EDGAR codes for all applicants in advance of the March 18, 2026, filing deadline. As a result, the staff provided limited no-action relief from the filing requirements. Specifically, the FAQs state that the...By: Wilson Sonsini Goodrich & Rosati
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