As stated on the Securities and Exchange Commission’s website, the SEC is currently preparing for a potential shutdown due to a lapse in appropriations. In the event of a shutdown, which would be in effect starting October 1, 2025, the SEC’s agency plans indicates that “the Commission will have only an extremely limited number of staff members available to respond to emergency situations.” The plan further calls for the continuing operation of certain SEC systems, including EDGAR. As reflected in the Division of Corporation Finance’s announcement, regardless of the SEC’s operating status, EDGAR will accept registration statements, offering statements and other filings; however, during a shutdown the SEC staff will not be able to declare registration statements effective nor qualify Form 1-A offering statements. The Division’s announcement covers additional FAQs in the event of a shutdown. Further, should a shutdown occur, Division staff will not be able to review or respond to shareholder proposal no-action requests, review preliminary proxy or information statements, nor provide interpretative guidance, no-action or exemptive relief other than, in limited circumstances. For additional information, see also a joint statement from the Divisions of Corporation Finance and Investment Management. For additional analysis concerning the possibility of a shutdown, see posts by Ropes & Gray, Simpson Thacher, Holland & Knight, Gibson Dunn and Davis Polk.