SEC Staff Extends Section 16 No-Action Relief for FPI Directors and Officers Affected by Middle East War

As Goodwin’s PCAP discussed in a recent client alert, the staff (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) Division of Corporation Finance on March 13, 2026 published a no-action letter confirming that the Staff would not recommend enforcement action for late filings by directors and officers of foreign private issuers (“FPIs”) who experience conditions that materially affected their ability to file timely Section 16(a) beneficial ownership reports that were originally due... By: Goodwin