Corporate and Financial Institutions Bulletin: SEC Reproposes Deregistration Requirements for Non-US Issuers

On December 22, the SEC reproposed new rules for a non-US company qualifying as a "foreign private issuer"1 to terminate its registration, and related SEC reporting obligations, under the US Securities Exchange Act of 1934 (the "Exchange Act"). Under the reproposed "exit rules", a company's ability to deregister would be determined primarily on the basis of the trading volume of its securities in the United States.