• Rule 12g3-2(b) Exemption from SEC Reporting
  • April 8, 2004 | Author: Mark S. Bergman
  • Law Firm: Paul, Weiss, Rifkind, Wharton & Garrison LLP - London Office
  • The Financial Times reported today that a UK company could inadvertently find itself subject to the reporting requirements of the US Securities and Exchange Commission or face other sanctions by reason of the belated discovery of American Depositary Receipts issued some years ago under an unsponsored program. The issue came to light when the company sought an exemption from the SEC reporting requirements and found that the number of holders of its securities (in this case, ADRs representing ordinary shares) exceeded the maximum number permitted for a company requesting such relief.