Rapid Growth of Unsponsored ADR Programs Following Recent Amendments to SEC Rule 12g3-2(b)
Client Memorandum

Created date

According to statements made by a number of market observers and regulators, over 700 unsponsored American Depositary Receipt (“ADR”) programs have been established in the weeks following recent changes to Rule 12g3-2(b) (“Rule 12g3-2(b)”) under the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”) and to the Securities and Exchange Commission (“SEC”) Form F-6 registration statement .