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Disproportionate Challenges for Smaller Public Companies
Treasury supports modifying rules that would broaden eligibility for status as an SRC and as a non-accelerated filer to include entities with up to $250 million in public float as compared to the current $75 million.
Treasury recommends extending the length of time a company may be considered an EGC to up to 10 years, subject to a revenue and/or public float threshold.
Treasury recommends that the SEC review its interval fund rules to determine whether more flexible provisions might encourage creation of registered closed-end funds that invest in offerings of smaller public companies and private companies whose shares have limited or no liquidity.
Treasury recommends a holistic review of the Global Settlement and the research analyst rules to determine which provisions should be retained, amended, or removed, with the objective of harmonizing a single set of rules for financial institutions.
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