Firm Memoranda

SEC Proposes Foreign Issuer Reporting Enhancements

Date: 03/10/08

In 1979 the Securities and Exchange Commission ("SEC") adopted Form 20-F for
use by foreign private issuers ("FPIs") when registering a class of securities and filing annual
reports in accordance with the Securities Exchange Act of 1934, as amended (the "Exchange
Act"). The principles guiding the implementation of this form was that investors should have
access to information concerning foreign private issuers that is equal, "as nearly possibly and
practicable", to the information available regarding domestic issuers while improving the accessibility
of public markets to foreign private issuers. Even at the time, however, the development
of foreign issuer disclosure requirements was acknowledged to be an evolutionary and iterative
process. On February 29, 2008, the SEC proposed a series of amendments pertaining to Form
20-F and a variety of related rules that the SEC believes would further both of these objectives
"in light of market developments, new technologies and other matters in a manner that promotes
investor protection, cross-border capital flows and the elimination of unnecessary barriers to
[U.S.] capital markets."1 The SEC has indicated that comments on the proposed amendments
should be received on or before May 12, 2008. A summary of the proposals follows.

CGRMemo_SEC Proposes Foreign Issuer Reporting Enhancements.pdf (pdf | 55.61 KB )