In this comment letter to the SEC the CAQ shares our views and provides input on the Securities and Exchange Commission’s (“Commission” or “SEC”) Release No. S7-2025-01, Concept Release on Foreign Private Issuer Eligibility (the “Concept Release”). Overall, the CAQ supports the Commission’s efforts to consider whether the current Foreign Private Issuer (FPI) definition should be revised and recommends the Commission consider:
- The impact of changes to the FPI definition on the financial reporting ecosystem outside the United States;
- Refining the eligibility criteria for the use of International Financial Reporting Standards as issued by the International Accounting Standards Board (IFRS-IASB) for dual listed registrants that are incorporated outside the United States;
- Providing transition provisions that provide enough time and flexibility to enable preparers to build the appropriate processes, systems and controls to report high quality financial information to investors in the shorter domestic registrant timelines; • Extending Smaller Reporting Company (SRC) accommodations to FPIs;
- Aligning the Foreign Business definition with the current definition of an FPI; and
- Modifying current FPI accommodations.
Read the full comment letter here.