More Insight into the Possible Direction of Regulatory Change

By: George M. Wilson & Carol A. Stacey


In early October, the U.S. Department of the Treasury published a report titled, “A Financial System That Creates Economic Opportunities: Capital Markets, Report to President Donald J. Trump, Executive Order 13772 on Core Principles for Regulating the United States Financial System”.


This 220-page report addresses many aspects of the capital markets, ranging from securitizations to derivatives. And, as you would expect, it addresses SEC regulation.


Among its recommendations are:


  • Repealing several Dodd-Frank disclosure requirements including the pay ratio and conflict minerals disclosure requirements


  • The SEC moving forward with the FAST Act requirements to review Regulation S-K


  • The SEC proceeding with the proposal to increase the threshold to be a Smaller Reporting Company to $250 million


  • Extending the time period a company can be an Emerging Growth Company to 10 years


  • Allowing all companies that are considering an IPO to “test the waters”


The report is an interesting read, and let us know if you have any thoughts or comments about the report!



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