Securities Regulation and Corporate Governance Monitor

Editor

Atma Kabad

Partner

Post-Shutdown Guidance for Registration Statements: Stay the Course or Get in Line

With the U.S. government reopening after a 43-day shutdown, the Securities and Exchange Commission Division of Corporation Finance (the “Division”) issued new Q&As on November 13, 2025 addressing certain post-shutdown issues, including the treatment of pending registration statements and proxy statements that were filed during the shutdown. Importantly, the guidance provides that: Issuers that filed…

Updated Guidance Regarding IPOs During the Shutdown

On October 9, 2025, the Securities and Exchange Commission (the “SEC”) Division of Corporation Finance updated Q&As addressing the implications of the government shutdown to help facilitate IPOs that companies seek to price during the government shutdown. Companies Can Launch IPO with Price Range Rule 430A allows companies to omit pricing and price-dependent information from…