Clifford Chance

New SEC Staff Guidance Extends FAST Act Financial Disclosure Relief and the JOBS Act Confidential Review Process to all Issuers, Including REITs

13 September 2017

The SEC Staff issued new guidance in the form of an amended Guidance Announcement and new Compliance and Disclosure Interpretations that (1) extend the financial disclosure relief granted by the FAST Act to Emerging Growth Companies filing on Form S-1 or Form F-1 to all issuers, even those that file on other Securities Act registration forms, including REITs, and (2) allow issuers to omit interim financial statements for historic periods if those interim periods will be covered by audited financial statements when the registration statement is publicly filed.

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