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23 July 2019
In June 2019, the SEC requested public comment on ways to simplify, harmonize and improve the exemptions from registration under the Securities Act of 1933. In this concept release, the SEC identified a number of topics to be addressed, including:
The SEC's press release and fact sheet about the review may be found at the following link: https://www.sec.gov/news/press-release/2019-97 A public comment period will be open for 90 days.
Any developments in this area will be of interest to the structured products industry. For example, the use of non-registered platforms for structured note offerings can reduce the SEC filing requirements, and reduce other offering expenses. In addition, non-registered offerings are not, strictly speaking, subject to the limitations on underlying assets that are imposed by the so-called Morgan Stanley/Reading Room letter.10 Additional flexibility for the use of non-registered offerings may broaden the use of these types of offerings in the future.
For further information on this topic please contact Lloyd Harmetz or James Schwartz at Morrision and Foerster's New York office by telephone (+1 212 468 8000) or email (email@example.com or firstname.lastname@example.org). Alternatively, please contact Jeremy Jennings-Mares or Peter Green at Morrison & Foerster LLP's London office by telephone (+44 20 7920 4000) or email (email@example.com or firstname.lastname@example.org). The Morrison & Foerster LLP website can be accessed at www.mofo.com.
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