On June 4, 2025, the SEC issued a concept release requesting input about the foreign private issuer definition.  The “Concept Release on Foreign Private Issuer Eligibility” focuses on how the population of foreign private issuers has changed since the origin of the definition and whether these changes necessitate updates to the definition.

The concept release lists several areas for comment, including:

• The existing FPI eligibility criteria,
• A foreign trading volume requirement,
• A major foreign exchange listing requirement,
• An SEC assessment of foreign regulation applicable to the FPI,
• New mutual recognition systems, and
• International cooperation arrangements.

You can read more in the related Fact Sheet and Press Release.

As always, your thoughts and comments are welcome!