SEC Issues New C&DI on Electronic Procedures under Regulation S, Rule 903
On December 8, 2016, the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) issued a new Compliance and Disclosure Interpretation number 277.05 relating to electronic procedures (the “C&DI”). The C&DI is directly relevant to the Forum’s involvement in canvassing market views on the London Stock Exchange’s implementation of electronic settlement procedures for Regulation S, Category 3 equity securities, (the “Category 3 Procedures”). Specifically, the C&DI supports a key element of the Forum’s Category 3 Procedures – that the certification and agreement required under Regulation S, including Category 3, can be provided electronically.