On February 27th, the SEC voted to approve final rule and form amendments under the Exchange Act that reflect recently adopted requirements under the Holding Foreign Insiders Accountable Act (HFIA), which enhance transparency into the holdings and transactions of officers and directors of foreign private issuers (FPIs). Pursuant to the HFIA, Section 16(a) was amended to require directors and officers of FPIs with a class of equity securities registered under Section 12 of the Exchange Act to disclose their holdings and transactions in the FPI’s equity securities
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