Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 04 APRIL 2019

Nasdaq Direct Listing Rules

Mayer Brown
Mayer Brown
Contributor
Mayer Brown

Mayer Brown

Mayer Brown is a leading international law firm positioned to represent the world’s major...

View firm profile
Explore more from Mayer Brown

Consistent with the rule adopted by the New York Stock Exchange in 2018 in order to facilitate direct listings, the Securities and Exchange Commission recently approved a similar Nasdaq rule

United StatesFinance and Banking
Anna T. Pinedo
Anna T. Pinedo
Author LinkedIn connections

Consistent with the rule adopted by the New York Stock Exchange in 2018 in order to facilitate direct listings, the Securities and Exchange Commission recently approved a similar Nasdaq rule for the Nasdaq Global Select Market, Rule IM-5315-1. Although prior to the effectiveness of the rule, the Nasdaq had permitted companies to undertake direct listings, the requirements were discretionary. The new rule clarifies the circumstances under which an issuer that has not previously registered a class of its securities under the Securities Exchange Act may list its securities without undertaking a public offering of its securities under the Securities Act. The Nasdaq will consider the market value of the securities of a company that have been trading on a private secondary market prior to the Nasdaq listing. Also, the Nasdaq rule allows Nasdaq to determine whether a company has met the market value of publicly held shares listing requirement for the exchange based on

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Visit us at mayerbrown.com

Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.

© Copyright 2026. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

OCC Issues Examiner Framework For Banks’ Use Of Artificial Intelligence

The Office of the Comptroller of the Currency has released a new framework for evaluating banks' deployment of artificial intelligence and agentic AI systems in their business operations. This guidance establishes how examiners will assess AI through existing risk management disciplines rather than creating separate regulatory requirements, with review intensity scaled to each use case's potential consequences and level of human oversight.
United StatesFinance and Banking
Sheppard
Sheppard
Article

23x5 Trading Comes To US Exchanges: What Firms Should Know Before Launch

US national securities exchanges are preparing to launch 23x5 trading by December 6, 2026, marking the most significant expansion of trading hours in decades. This comprehensive analysis examines the regulatory approvals, operational infrastructure changes, investor protection mechanisms, and issuer considerations necessary to support overnight equity trading from Sunday through Thursday evenings.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

SEC Proposes Rule Amendments To Expand Retail Access To Private Markets

The SEC has proposed sweeping amendments to expand retail investor access to private market strategies, including changes to performance-based compensation rules for registered investment advisers and modernization of the interval fund framework. The proposals also explore new credential-based pathways for individuals to qualify as accredited investors, potentially opening private offerings to a broader pool of eligible participants.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

DOL Announces Enforcement Actions Against Employers In H-1B And PERM Fraud Probe

The Trump Administration has launched an unprecedented enforcement action suspending permanent labor certification processing for eight major employers, linking immigration sponsorship to layoff histories and recruitment practices. This development signals a fundamental shift in how the government evaluates employer access to H-1B and green card programs, with investigations already underway and subpoenas served.
United StatesEmployment and HR
Mayer Brown
Mayer Brown
Article

Landmark DoorDash Settlement Confirms NYC DCWP’s Aggressive Enforcement Posture

New York City's Department of Consumer and Worker Protection secured a landmark $131.5 million settlement with DoorDash, marking the largest worker settlement in the city's history and the largest involving food delivery workers nationwide. The agreement provides over $115 million in direct compensation to more than 260,000 delivery workers who were underpaid, unpaid, or paid late, while establishing a comprehensive three-year compliance monitoring program.
United StatesEmployment and HR
Mayer Brown
Mayer Brown
Article

Trump Administration Announces New Enforcement Actions Against Employers In H-1B And PERM Fraud Probes

The Trump Administration has launched an unprecedented investigation into H-1B visa and PERM labor certification programs, with the Department of Labor's Office of Inspector General issuing dozens of subpoenas and suspending employers' ability to process applications. Federal agencies are deploying new enforcement tools including whistleblower programs and criminal prosecution threats...
United StatesImmigration
Mayer Brown
Mayer Brown
Article

EU’s CBAM Downstream Extension And Anti-Circumvention Amendments: The Road To Trilogue

The European Union's Carbon Border Adjustment Mechanism is undergoing critical legislative refinement as the Commission, Council, and Parliament have each established distinct positions on extending CBAM to downstream goods and strengthening anti-circumvention measures. With trilogue negotiations now underway and the first political trilogue scheduled for October 2026, significant divergences remain between the institutions on scope, exemptions, and enforcement mechanisms that will shape the final framework
European UnionEnvironment
Mayer Brown
Mayer Brown