SEC Limits Policy re Non-Public Filing of Registration Statements by Foreign Registrants

December 13, 2011

On December 8, 2011, the Division of Corporation Finance of the Securities and Exchange Commission ("SEC") announced that effective immediately it was limiting its policy with respect to the non-public submission of initial registration statements by foreign private issuers.

CGR Memo - SEC Limits Policy re Non-Public Filing of Registration Statements by Foreign Registrants