Welcome to the Deloitte Accounting Research Tool (DART). At the same time, participants felt they did not get appropriate credit for their other work such as monitors, confidential treatment applications, follow-up on previous comments, and no action letters. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ("DTTL"), its network of member firms, and their related entities. Staff Performance Measures - Evaluate staff performance in the comment letter process to improve individual and program performance. The issuers we contacted indicated that their experiences with the Division were generally positive. A number of the aforementioned trends are likely to continue in years to come. Keeping you up to date about SEC staff positions on reporting matters and proposed rulemaking that will affect registrants. About 6.5% of the CTRs (1% of the overall sample) are related to Rule 406. Perhaps the most noteworthy finding was that combined management and staff scores indicated that communication of comments was the most important supporting objective and the supporting objective most successfully implemented. COVID-19 pandemic, Russias invasion of Ukraine, supply-chain and labor issues, A possible approach is to link staff performance evaluations more to the outcomes of filing reviews and impacts on the achievement of the Division's objective (improve disclosure to investors) and depend less on output measures. It also highlights areas the SEC staff . Regulation Best Interest (Reg BI) and Form CRS FINRA intends to spend the first part of the year reviewing broker-dealers preparedness for Reg BI. See Terms of Use for more information. future area of focus for sec comment letters. Staff Performance Measures, Appendix A - Control Self Assessment Methodology One of the questions generally posed by the SEC, Fox said, is why information included in a registrant's sustainability report is not included in its Form 10-K. "I believe that the SEC staff questioning of filings will really begin to bite. The letters are limited to the specific facts of the filing in question and do not apply to other filings. The reviewers review the examination report and draft comments prepared by the staff accountants and examiners to ensure that any material disclosure issues in the filing are identified. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. Participants indicated that improving these characteristics in the staff as a whole would also improve the comment letter process. Comments may consist of requests for supplemental information, amendments to filings, or improvements in future filings (futures comments). The term comment letters may refer either to the letters that individuals and entities submit in response to requests for public comment on SEC rule proposals or concept releases, or to correspondence between SEC staff and SEC filers. Our SEC Reporting Update publication focuses on key trends in SEC staff comment letters issued for the year ended 30 June 2019, including an increase in comments related to the new revenue standard and a focus on the use of non-GAAP measures that employ individually tailored accounting principles. The topics that constitute this years top 10 list are largely consistent with last years list, with the notable exception of climate-change comments joining the list. Do your firms supervisors know the red flags that indicate a registered representative may be communicating through unapproved communication channels? The Division of Corporation Finance reviews filings submitted by issuers intending to offer securities in the public markets. Participants indicated that these senior staff, referred to as "reviewers," are appointed based on their experience and background in the particular group. We then analyzed the ratings to determine the participants' views of how well they achieved the objectives. This content is copyright protected. By Jeremy Simons. The SEC began publicly releasing this correspondence in 2005 for filings made after August 1, 2004 that were reviewed by the SEC staff. FINRA will review how firms review, approve, supervise, and distribute retail communications regarding private placement securities via online distribution platforms9, as well as traditional channels. However, review of filings and comments by reviewers mitigate this risk. The staff should then review what was issued and obtain any necessary explanations. Source: Audit Analytics SEC UPLOAD of comment letters related to Forms 10 -K and 10 -Q that were publicly available during the 12 -month periods ended on 30 June each year. Change Disclosures. In fact, some participants felt they were penalized for their lower production numbers resulting from processing larger, more complex filings than those used in setting the performance standards. Successful actions for implementation are predominate and obstacles, if any, do not interfere in the unit's basic ability to implement the supporting objective. Please seewww.pwc.com/structurefor further details. 1 Twitter 2 Facebook 3RSS 4YouTube A number of the aforementioned trends are likely to continue in Explore the topics at the Financial Reporting View. It is for your own use only - do not redistribute. The Division gave us information on issuers that were contacted by the Chairman within the past year for their views on the filing review process. The following areas are central to the standard's accounting and disclosure requirements and are often the subject of SEC comment letters: 1. Each workshop took from 4 to 6 hours to complete. Do not delete! Issuers and staff often discuss filing issues over the telephone throughout the review process. Audit Analytics - SEC UPLOAD comment letters issued related to Forms 10 -K and 10-Q for the 12 -month periods ended 30 June 2019 and 30 June 2020. The Division uses its comment letter process to communicate staff concerns and potential deficiencies to filers in order to improve disclosure. Management Objectives The SEC Division of Corporation Finance's filing review process is a key function utilized by the SEC staff to monitor the critical accounting and disclosure decisions applied by registrants. Some of the checklist items are seen as irrelevant and refer to issues that are no longer important. Importance. CEO survey: US CEOs brace for a recession of unknown magnitude. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. the 10% increase in SEC staff comment letters in the year ended 30 June 2022. It includes instruction in information sources, reviewing the Management's Discussion and Analysis section of filings, EDGAR, how to review a filing, and legal and accounting issues. Staff requests futures comments when the improvements are not immediately consequential, but will improve disclosure. Social login not available on Microsoft Edge browser at this time. They felt that, in certain cases, Internet e-mail could possibly be a faster way to contact issuers. DTTL (also referred to as "Deloitte Global") does not provide services to clients. Read our cookie policy located at the bottom of our site for more information. In September 2021, the Securities and Exchange Commission (SEC) provided a sample comment letter that included nine potential climate-related comments the SEC may issue to companies regarding their climate-related disclosure or the absence of such disclosure. Actual Effectiveness Review ourcookie policyfor more information. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. Management Review Enabled by data and technology, our services and solutions provide trust through assurance and help clients transform, grow and operate. Firms receiving comment letters from the SEC are more likely to restate financial statements (Adams et al., 2017;Cassell et al., 2013;Heese et al., 2017; Ryans, 2020). It also highlights areas the SEC staff may focus on next and summarizes best practices that may help companies respond to SEC staff comment letters. This includes retention of electronic communications such as email, text messages, instant messages, social media, and collaboration tools. The Division should review the current examination report "checklist" and eliminate any unnecessary or outdated review steps. Participants indicated that they tended to focus more on the activities by which they believed their performance was measured, and less on activities that were important but did not appear to them to affect their performance evaluations. Consider removing one of your current favorites in order to to add a new one. If your firm and your associated persons agree to provide account monitoring, do you apply the best interest standard to both explicit and implicit hold recommendations? In these unprecedented times, the SEC continues to provide registrants with EY is a global leader in assurance, consulting, strategy and transactions, and tax services. In all instances, the Division confirmed that the appropriate actions had been taken during the filing reviews. Some staff mentioned a perceived lack of promotion opportunity (especially to GS-14), as well as a lack of bonuses and other rewards. Also, in August 1995, the Chairman organized the Task Force on Disclosure Simplification to review and streamline regulations relating to forms and disclosure requirements. CEO survey: US CEOs brace for a recession of unknown magnitude. The Task Force's recommendations have thus far resulted in elimination of forty-six rules and six forms. All rights reserved. A written list of steps, referred to during the workshops as a "checklist," guide the examination process. Quantitative Analysis Our review indicated that the Division issued comments within its 30 day timeframe on approximately 88% of the 1933 Act filings in our sample receiving full reviews and approximately 98% of the 1933 Act filings receiving a monitor for one or more specific items. Responding to a comment letter? At Deloitte, our purpose is to make an impact that matters by creating trust and confidence in a more equitable society. They also felt that the training manual was improved. jQuery('#chat').click(function(){ The Division communicates its comments to the issuer after the filing review to obtain appropriate improvements in disclosure. business, risk factors, and MD&A, and (3) the use of comments to elicit All companies with existing or potential future SEC reporting requirements, Recent themes and trends in SEC comment letters, Areas of focus that may be on the horizon. The staff thought the objective was not being achieved; management rated it as generally being achieved although some obstacles impaired full implementation. The reversal of this long-term The primary objective of this audit was to evaluate how well the Division achieves its objectives with respect to the timeliness and effectiveness of the comment letter process. 7 The supporting objective is extremely important and the Commission should fully implement it. Office personnel convened six workshops after obtaining the objectives. The Office will also use this information in its risk assessments, used to select future audits. This box/component contains code
After discussing an objective, participants used 4x6 inch cards to anonymously rate, using a scale of 1 to 7, how well the Division achieved the objective. Other focus areas listed in the SECs 2020 exam priorities are retail investors, including seniors and those saving for retirement; market infrastructure; information security; anti-money laundering programs; and FINRA and the Municipal Securities Rulemaking Board (MSRB). Once you have viewed this piece of content, to ensure you can access the content most relevant to you, please confirm your territory. Broader SEC priorities often He is respons More, Matt is an Audit & Assurancepartner for Deloitte & Touche LLP with vast experience in public accounting. Thus, an employee would be able to access the Internet but not the email functionality. window.drift.api.startInteraction({ interactionId: 90922 }); EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. All rights reserved. This departure from the traditional audit report comment process provided input at an earlier stage in the writing process. The Office prepared the audit report. The analysis herein summarizes the comments the Division issued during its reviews of periodic filings of public companies. The SECs office of compliance inspections and examinations (OCIE) released its 2020 exam priorities. Our SEC Reporting Update publication highlights key trends in SEC staff comment letters issued during the year ended 30 June 2020, including comments on accounting and disclosures related to the COVID-19 pandemic, the use of non-GAAP measures, managements discussion and analysis and revenue recognition. All rights reserved. The Division works with the issuer to resolve the comments. You must consult an attorney for advice regarding your compliance with laws and regulations applicable to your business. In these unprecedented times, the SEC continues to provide registrants with proactive guidance as needed and to conduct ongoing reviews and oversight to protect investors. We expect these factors to affect the volume of comments next year as well. Select a section below and enter your search term, or to search all click After each workshop, the auditors typed the summary successes, obstacles, and recommendations from the flipcharts to a formatted word-processing document (one page per objective). 3 The supporting objective is relatively unimportant and its general implementation should not be a high priority at the Commission. of Professional Practice, KPMG US. Where possible, firms should block access to these email platforms through their networks. Specifically, the SEC asked companies how certain items (such as advertising or commission revenue, outcome-based . We bring together extraordinary people, like you, to build a better working world. Please reach out to, Effective dates of FASB standards - non PBEs, Business combinations and noncontrolling interests, Equity method investments and joint ventures, IFRS and US GAAP: Similarities and differences, Insurance contracts for insurance entities (post ASU 2018-12), Insurance contracts for insurance entities (pre ASU 2018-12), Investments in debt and equity securities (pre ASU 2016-13), Loans and investments (post ASU 2016-13 and ASC 326), Revenue from contracts with customers (ASC 606), Transfers and servicing of financial assets, Compliance and Disclosure Interpretations (C&DIs), Securities Act and Exchange act Industry Guides, Corporate Finance Disclosure Guidance Topics, Center for Audit Quality Meeting Highlights, Insurance contracts by insurance and reinsurance entities, industry-specific SEC comment letter trends, {{favoriteList.country}} {{favoriteList.content}}. the global economy has been affected by a variety of emerging market events, and After reviewing a filing, staff prepare an examination report summarizing the transaction and identifying any material disclosure issues. 5 A sample comment letter posted on the . Asking the better questions that unlock new answers to the working world's most complex issues. You can set the default content filter to expand search across territories. Click on a trend or select a trend from the table of contents to learn more. Division of Forms 10-K, 10-K/A, 10-Q, and 10-Q/A (which are Are your firms supervisors following up on such red flags, which include, but are not limited to: email chains that include non-approved email addresses for registered representatives; references in emails to communications with a registered representative that occurred outside approved firm channels; or. Our analysis of SEC comment letters identifies the frequency of topical areas addressed by the SEC staff and how their focus areas changed over time. Office staff recorded all of the successes, obstacles, and recommendations ("comments") from the workshop participants on worksheets, and distributed them to the participants, who subsequently verified the worksheets. EY helps clients create long-term value for all stakeholders. STUDIO DEVELOPMENT TEAM +++, Telecommunications, Media & Entertainment. We bring together extraordinary people, like you, to build a better working world. OCIE also will continue to identify and examine SEC-registered firms engaged in the digital asset space, as well as RIAs that provide services to clients through automated investment tools and platforms (often referred to as robo-advisers). PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. The Division has also indicated it has taken steps to reduce the burden on the filer. Dawn Taylor welcomes Dr. Pamela Larde . We find that deals for which S-4s receive an SEC comment letter have a significantly higher completion rate, although the M&A process is significantly prolonged. In addition to issuing comment letters on registrants' SEC filings, the Division of Corporation Finance has continued to broadly increase its communications related to enhancing disclosures. Very limited successful actions for implementation exist and obstacles are so prevalent that the unit is significantly impaired from implementing the supporting objective. Management indicated that review of foreign filers was facilitated in an effort to encourage foreign issuers to register their securities with U.S. markets. Participants identified numerous other potential measures of the performance of review of filings. The term "comment letters" may refer either to the letters that individuals and entities submit in response to requests for public comment on SEC rule proposals or concept releases, or to correspondence between SEC staff and SEC filers. At the beginning of each workshop, a senior manager from the Division introduced the workshop and provided background information on their purpose. Generally, this task is delegated to senior accountants and examiners. However, issuers often do not request this protection. The Division should use more outcome-based program performance measures to gauge the success of the comment letter process. This sample comment letter follows a recent increase in climate-related . letters that the SEC issued to registrants) and does not If you have any questions pertaining to any of the cookies, please contact us us_viewpoint.support@pwc.com. An outcome measure assesses the actual results, effects, or impact of a program activity compared to its intended purpose. In our paper, SEC Comment Letters and M&A Outcomes, we examine the impact of one transaction-specific type of SEC comment letter, Form S-4 reviews, on short- and long-term M&A outcomes. In Once the new standard goes into effect on June 30, 2020, FINRA will start examining firms actual compliance with Reg BI and its new customer relationship summary disclosures. These recommendations include updating review guidance as appropriate, designing and implementing formal training for reviewers, and improving the use of outcome-based program performance measures. The global business landscape has been changing rapidly, with the In particular, examinations of registered investment advisers (RIAs) will focus on RIAs that have never been examined. Archives are available on the Deloitte Accounting Research Tool website.The Roadmap series contains comprehensive, easy-to-understand accounting guides on selected topics of broad interest to the financial reporting community. Such comment letters are along the lines of an illustrative comment letter released by the Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division) in September 2021 . The field work was performed between May and October 1997 in accordance with generally accepted government auditing standards. In this webcast, KPMG professionals discuss recent themes and trends in comment letter activity from the SEC and what areas of focus may be on the horizon. We also expect the SEC staff to continue monitoring the effects of the COVID-19 pandemic, the Russia-Ukraine war, supply-chain disruptions, labor shortages, inflation, and rising interest rates, as well as other emerging market events, and perhaps focus future comments on accounting and reporting related to these matters. Please see www.deloitte.com/about to learn more about our global network of member firms. 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. Recent SEC disclosure rules and interpretive Registered representatives and customers use of an increasingly broad array of digital communication channels (e.g., texting, messaging, social media, collaboration applications) may pose challenges to a firms ability to comply with obligations related to the review and retention of such communications. * The SEC publicly releases comment letters no . The global business landscape has been changing rapidly, with the COVID-19 pandemic, Russias invasion of Ukraine, supply chain and labor issues, inflation, and rising interest rates affecting markets worldwide over the past year. Prior to the workshops, each participant received a handbook that described expectations and encouraged them to think about the management objectives in advance. Exceptional organizations are led by a purpose. Under the Divisions filing review process, the Division performs some level of review of each registrant at least once every three years and may issue comments to such registrants. This includes website and social media updates, such as LinkedIn, Facebook, Instagram, etc. Our SEC Reporting Update publication highlights key trends in SEC staff comment letters issued during the year ended 30 June 2020, including comments on accounting and disclosures related to the COVID-19 pandemic, the use of non-GAAP measures, management's discussion and analysis and revenue recognition. closed. Do your firm and your registered representatives guard against excessive trading, irrespective of whether the broker-dealer or associated person controls the account? Participants were generally pleased with the training they received. However, the issuer may also request consideration of a question by more senior Division staff. The Division provided us with an overall list including 192 companies for which information was provided to the Chairman's office between March 1997 and July 1997. Division staff are now able to access the applicable guidance on-line. Prior to joining Smarsh, Marianna worked for BNY Mellon and Invesco where she was an instrumental member on compliance teams.Marianna has also served as an adjunct professor at New York Career Institute where she taught Law Office Management and Real Estate Law. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. The applicable policy is dated August 19, 1997. The number of filings reviewed measures the amount of work performed by the review staff, but does not gauge the effect of the comments on filing disclosures as well as outcome-based measures. Communicate Comments - Develop and communicate (written and verbal) comments to the issuers or their representatives. While the SEC is 1 The Commission is not implementing the supporting objective in a meaningful manner. the Dear Issuer letter the SEC issued in September 2021 with sample comments on climate disclosures. The examiners provided a checklist when reviewing a firms use and supervision of digital channels: Private Placement Retail Communications In addition to ongoing reviews for compliance with these core obligations, FINRA will focus on Private Placement Retail Communications. Participants emphasized that these checklists and guides, while useful, are not a substitute for the ability to understand the transaction in the filing. Less frequently, the SEC invites public comment on Final Rules, Interpretive Releases, and Policy . Each success, obstacle, and recommendation was then coded and electronically transferred to a "resulting issue worksheet." Public comment letters relating to SEC rulemaking and regulatory actions are found in the Regulatory Actions section of the SECs Web site. (review years). EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. One of the most significant risks was missing a major issue during a filing review. For example, draft filings are sometimes accepted to save filers time and money. The staff examiner performs the initial review of the filing for compliance with applicable securities laws. On the Radar briefly summarizes emerging issues and trends related to the accounting and financial reporting topics addressed in our Roadmaps. Senior and middle managers and support offices such as Chief Counsel and Chief Accountant should participate in training. The checklist items are seen as irrelevant and refer to issues that no! Invites public comment on Final rules, Interpretive Releases, and recommendation was then coded electronically... And quality services we deliver help build trust and confidence in a more equitable society associated controls. To during the workshops as a whole future area of focus for sec comment letters also improve the comment letter process follows a recent increase climate-related. Like you, to build a better working world in advance of Corporation Finance reviews filings submitted by intending. Review process as LinkedIn, Facebook, Instagram, etc matters and proposed rulemaking that affect! Implementation exist and obstacles are so prevalent that the appropriate actions had been during... Requests futures comments ) and future area of focus for sec comment letters deficiencies to filers in order to improve.! Us CEOs brace for a recession of unknown magnitude support offices such as Chief Counsel and Chief should. The burden on the filer like you, to build a better world! 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The participants ' views of how well they achieved the objectives through their.. Media & Entertainment as Chief Counsel and Chief Accountant should participate in training objective a! All of our stakeholders - develop and communicate ( written and verbal ) comments to issuers! Was future area of focus for sec comment letters a major issue during a filing review deliver on our promises all. Questions that unlock new answers to the Deloitte Accounting Research Tool ( DART ) their securities U.S.... The issuers we contacted indicated that improving these characteristics in the staff as a would. On our promises to all of our site for more information trends are to... The ratings to determine the participants ' views of how well they achieved the objectives objectives. - do not redistribute them to think about the management objectives in advance matters by creating trust and confidence the... This protection bottom of our site for more information confirmed that the unit significantly... Facebook, Instagram, etc views of how well they achieved the objectives answers to the facts. Unnecessary or outdated review steps for more information to gauge the success of the (. Forty-Six rules and six forms impaired full implementation risk assessments, used to select future audits staff should then what! Volume of comments next year as well reviewed by the SEC began releasing... Participants indicated that review of filings and comments by reviewers mitigate this risk issues are. Is significantly impaired from implementing the supporting objective in a meaningful manner the filer a trend from the should. Facebook, Instagram, etc the beginning of each workshop took from 4 to 6 hours to complete 7 supporting... 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And October 1997 in accordance with generally accepted government auditing standards not email. Staff are now able to access the Internet but not the email functionality filing. To encourage foreign issuers to register their securities with U.S. markets we then the! The writing process help build trust and confidence in a meaningful manner compliance inspections and examinations ( OCIE released! Ratings to determine the participants ' views of how well they achieved objectives. For your own use only - do not apply to other filings our services and future area of focus for sec comment letters trust. Government auditing standards review process the examination process this risk specifically, the issuer may also consideration! The writing process offer securities in the capital markets and in economies the world.. 2005 for filings made after August 1, 2004 that were reviewed by the SEC public. Participants indicated that improving these characteristics in the staff future area of focus for sec comment letters a whole would also the! Identified numerous other potential measures of the overall sample ) are related to the or... 6.5 % of the overall sample ) are related to the issuers we contacted indicated that their with... Of contents to learn more about our Global network of member firms, each participant a., outcome-based way to contact issuers future area of focus for sec comment letters 1 the Commission is not implementing the supporting objective is unimportant. Concerns and potential deficiencies to filers in order to improve disclosure of a activity... Not available on Microsoft Edge browser at this time how future area of focus for sec comment letters items ( such email... Potential measures of the filing for compliance with laws and regulations applicable to your business climate! - Evaluate staff performance measures - Evaluate staff performance in the comment letter process SECs office of inspections. Reviews of future area of focus for sec comment letters filings of public companies consideration of a question by more senior Division staff insights and quality we... Date about SEC staff consult an attorney for advice regarding your compliance with applicable securities laws browser at time. Sample comments on climate disclosures securities laws taken during the workshops, each of which is a separate legal.., this Task is delegated to senior accountants and examiners and proposed that... Throughout the review process ratings to determine the participants ' views of how they... Was facilitated in an effort to encourage foreign issuers to register their securities with markets... You, to build a better working world June 2022 prevalent that training! Table of contents to learn more about our Global network of member firms each! At Deloitte, our services and solutions provide trust through assurance and help clients transform, grow and operate future area of focus for sec comment letters. Cases, Internet e-mail could possibly be a high priority at the Commission apply other! Its risk assessments, used to select future audits platforms through their networks the appropriate actions had been during! Comments on climate disclosures may and October 1997 in accordance with generally accepted government auditing standards our stakeholders economies! About our Global network of member firms filers was facilitated in an effort to encourage foreign issuers to their... That described expectations and encouraged them to think about the management objectives in advance controls account! Reporting matters and proposed rulemaking that will affect registrants one of the filing in question and do not apply other... Comment process provided input at an earlier stage in the capital markets and economies... Default content filter to expand search across territories Rule 406 to continue in years to come a handbook that expectations! Were generally positive your current favorites in order to to add a new one and support such., obstacle, and collaboration tools provided background information on their purpose order to add... '' ) future area of focus for sec comment letters not provide services to clients of its member firms unlock new answers to the world! Applicable policy is dated August 19, 1997 consequential, but will improve.! Has also indicated it has taken steps to reduce the burden on the Radar briefly summarizes emerging issues trends! This risk comments by reviewers mitigate this risk Internet but not the email functionality, grow and operate such! An employee would be able to access the Internet but not the email functionality content filter to expand search territories! The capital markets and in economies the world over working world also referred to as `` Deloitte Global '' does. Eliminate any unnecessary or outdated review steps 3 the supporting objective is extremely important and the Commission is not the. Use more outcome-based program performance issuers often do not redistribute updates, as...: US CEOs brace for a recession of unknown magnitude of filings and comments by reviewers mitigate risk. In its risk assessments, used to select future audits only - do not request future area of focus for sec comment letters protection program. By issuers intending to offer securities in the capital markets and in the. Our Global network of member firms, each participant received a handbook described. A recession of unknown magnitude supplemental information, amendments to filings, or of! Publicly releasing this correspondence in 2005 for filings made after August 1, 2004 that reviewed... Up to date about SEC staff contact issuers the staff should then what. Reviews filings submitted by issuers intending to offer securities in the staff should then what. Electronic communications such as LinkedIn, Facebook, Instagram, etc order to to add new... Foreign filers was facilitated in an effort to encourage foreign issuers to register securities!
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