Matthew E. Barsamian

On May 19, 2026, the SEC proposed two interrelated rule packages that, taken together, would fundamentally restructure the framework governing reporting company filer status under the Exchange Act and the registered securities offering process.1 While the Proposals have broad implications across the public markets, this Dechert OnPoint focuses on the aspects of the Proposals that have particular significance for BDCs and CEFs. The Proposals are more broadly covered in a previously published...

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U.S. financial services providers who transacted in financial services with non-U.S. persons in the 2024 fiscal year may be required to file the Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons (BE-180) by July 31, 2025 (unless they obtain an extension).