This streamlined process requires the submission of a one-page application by which a company can affirm that the most recently considered CTR application continues to be true, complete and accurate regarding the information for which the company continues to seek confidential treatment. … More
Monthly Archives: April 2019
Trap for the unwary: you still need to renew confidential treatment requests filed under the old rules
A confidential treatment order for information redacted from an exhibit is about to expire. Under SEC rules that took effect last week (see our prior blog posts here and here), public companies can now redact the same type of information without prior SEC review, so the company doesn’t have to do anything, right?
Wrong. The SEC has confirmed that its new rules for the redaction of confidential information from certain exhibits do not automatically extend orders for confidential treatment granted under the traditional application process.… More
The SEC staff has issued supplemental guidance regarding its new rules for the redaction of confidential information from certain exhibits, which take effect today. See our blog post here for more detail on the new rules.
Consistent with prior practice, a company redacting information from a material contract must:
- note in the exhibit list that portions of the exhibit have been omitted;…