The last two mandatory compliance dates under the SEC’s amendments to Exchange Act Regulation 13D-G adopted in October 2023 are fast approaching. We discussed the amendments in our SEC Update available here.
Beginning on September 30, 2024, filers that report their beneficial ownership of a covered class of equity security on Schedule 13G will be required to comply with accelerated filing deadlines for initial and amended filings.
Beginning on December 18, 2024, reporting persons will be required to file their Schedules 13D and 13G using a structured, machine-readable data language.
In its filing review process this year, the SEC’s Division of Corporation Finance has been commenting on non-compliance with the shorter Schedule 13D reporting deadlines that became effective on February 5, 2024. Filers should expect the SEC staff to scrutinize the timeliness of Schedule 13G filings under the new deadlines for those schedules.
Authored by Alan Dye (co-editor), Richard Parrino (co-editor), Kevin Greenslade, Evan Koster, Weston Gaines, Gibby Wagner, and Spencer Leroux.
