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Updated Shutdown FAQs re IPOs from SEC Division of Corporation Finance

By Emerald Greywoode posted 10-10-2025 05:47 AM

  

On October 9, the SEC’s Division of Corporation Finance updated its guidance to provide regulatory relief to IPO companies and other companies seeking to proceed with public offerings during the shutdown. In the marked version that the Division posted, staff explained that because they are not available to review or accelerate the effectiveness of registration statements during the shutdown, they would not recommend enforcement action to the SEC’s Division of Enforcement if a company relies on Rule 430A under the Securities Act of 1933 to omit pricing information from the form of prospectus filed as part of a registration statement during the shutdown. For additional analysis see the posts by Ropes & Gray, Simpson Thacher, Freshfields.

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