On March 9th, the staff of the SEC’s Division of Corporation Finance published a list of answers to FAQs concerning the implementation of the Holding Foreign Insiders Accountable Act (HFIA Act). The list of responses addresses the obligations of directors and officers of foreign private issuers with a class of equity securities registered under Section 12 of the Exchange Act and which are preparing for their first filings under Section 16(a) of the Exchange Act as a result of the effectiveness of the HFIA Act. On December 18, 2025, the President signed into law the HFIA Act, which will be effective on March 18, 2026.
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