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 banks, financial intermediaries and exchanges, following a roundtable and additional written comments.

The comment letter included suggestions to aid in the Commission’s efforts to harmonize the framework of the US Securities Act of 1933, while maintaining investor protections and easing the burdens on issuers and other offering participants. Such suggestions included: (i) the extension of federal preemption to additional offers and sales of securities involving accredited investors; (ii) the addition of further disclosure requirements for retail investors investing in pooled or other investment strategies; and (iii) the simplification of the initial public offering process in order to encourage more public offerings.

The full comment letter can be viewed HERE.

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