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ARTICLE · 09 MAY 2019

UPDATE: SEC Adopts Streamlined Process For CTR Extensions

Foley Hoag LLP
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Just hours after our recent blog post regarding the need to use the traditional process for CTR extensions, the SEC announced the adoption of a new streamlined process for CTR extensions.

United StatesCorporate/Commercial Law
Ryan M. Rourke Reed
Ryan M. Rourke Reed
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Just hours after our recent blog post regarding the need to use the traditional process for CTR extensions, the SEC announced the adoption of a new streamlined process for CTR extensions.

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. In addition, the company must indicate the period of time for which it is requesting an extension of confidential treatment (either three, five or ten years) and provide a brief explanation to support the request. There is no need to refile the unredacted documents with the request nor provide a supporting analysis if the analysis remains the same as presented in the most recent CTR application. Notably, the SEC indicated that if the company determines that certain information has been publicly

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