SEC Updates Tender Offer Compliance and Disclosure Interpretations

On March 17, 2023, CorpFin updated several Compliance and Disclosure Interpretations (C&DIs) related to tender offers.  The updates address a wide range of questions.  For example, one of the C&DIs clarifies that a tender offer may be subject to conditions only when the conditions are based on objective criteria.  Other examples discuss who is a bidder in the tender offer process.  You can find the updated C&DIs here.

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