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Category Archives: Letters

Letters | 26 Sep 2019
SEC Comment Letter: Private Placements Concept Release. On 24 September 2019,  The Forum For US Securities Lawyers in London submitted a comment letter to the  U.S. Securities and Exchange Commission in response to the “Concept Release on Harmonization of Securities Offering Exemptions” issued on 18 June 2019 by the Commission. The comment letter was produced by a working group of the Forum including law firms, investment ...
Letters | 5 Oct 2012
JOBS Act – SEC Comment Letter (Revised). View Letter Here   Via Email: rule-comments@sec.gov October 5, 2012 U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Attention: Ms. Elizabeth M. Murphy, Secretary Re: Request for Public Comments on SEC JOBS Act Provision about General Solicitation and Advertising in Securities Offerings Dear Ms. Murphy: This letter is submitted on behalf ...
Letters | 12 Jun 2012
Comment Letter on the JOBS Act from the Forum for U.S. Securities Lawyers in London. Year 2 Project – Regulation S, Category 3 Year Two Project Investment Company Act Section 3(c)(7) Model Procedures for Equity Issuances in the London Capital Markets In July 2012 the Forum submitted a comment letter with respect to the rules the Securities and Exchange Commission (the “Commission”) is required to adopt pursuant to the Jumpstart ...
Letters | 4 Sep 2008
Rule 15a-6 Comment Letter (September 2008). The comment letter generally supports the Commission’s efforts to expand the scope of activities that a foreign broker-dealer could conduct in the United States without the need for registration and the simplification of procedures and the increased direct access and interaction with U.S. investors that the Proposals envisage. However, there are some areas where we ...
Letters | 4 Jun 2008
Cross Border Tender Offer Proposal Comment Letter (June 23, 2008). The letter comments on the Cross-Border Tender Offer Proposal in the following areas: a) Support for raising the Tier 1 exemption threshold to 15%; b) Comments on proposals related to the U.S. ownership calculation date for negotiated and non-negotiated transactions, including: Support of change to announcement date as reference date; Support of allowance of a ...
Letters | 4 Apr 2008
Rule 12g3-2(b) Comment Letter (April 2008). Regulation D Comment Letter (October 2007) Annual Report 2008 The comment letter generally supports the SEC’s attempt to modernize the exemption regime under Section 12(g) for foreign private issuers. However, there were again some areas where we suggested modifications or alternative approaches to the Proposals. The letter includes comments for the SEC in the following ...
Letters | 4 Oct 2007
Regulation D Comment Letter (October 2007). The comment letter generally supports the efforts to rationalize and streamline the law applicable to offerings that are not registered under the Securities Act. It argues that in the light of recent market and technological developments, the laws relating to private offerings need to be revisited. However, with respect to the SEC Proposal to revise ...

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