We are pleased to share with you the final comment letter submitted on 8 September 2025 to the SEC in response to its Concept Release on the proposed changes to the definition of “Foreign Private Issuer.”  This letter reflects the outcome of extensive engagement through our roundtable discussions, virtual working group and one-on-one meetings, and written feedback.

We would like to extend our sincere thanks to Cleary for their invaluable support in preparing this submission.

We are also grateful to all members of the working group who contributed their time and insights throughout this process.

The letter can be viewed or downloaded by clicking here.

Warm regards,
The Forum for US Securities Lawyers in London Leadership Committee

Connie Milonakis, Partner, Capital Markets, Davis Polk
Miriam Patterson, Senior Director, Market Practice & Regulatory Policy, ICMA (Co-Chair)
Jennifer Y. Poon, Associate General Counsel – Group Corporate & Governance, Unilever
Laura Sizemore, Partner and Head of EMEA Capital Markets, White &Case
Deborah Smith, Executive Director, Global Policy & Docs Leadership – Head of Risk Pillar, Goldman Sachs
Daniel Winterfeldt MBE KC (Hon), General Counsel EMEA & Asia, Jefferies (Co-Chair)