Title

SEC Shutdown: Pointers for Capital Markets Transactions
Client Memorandum

Created date

12/21/2018

The SEC will be closed for the holidays on December 24 and 25. In addition, in the event of a government shutdown, the SEC said it would “remain fully operational for a limited number of days,” conducting ordinary business. It did not specify what that limited period would be. The SEC said non-WKSI companies that do not have an effective shelf registration statement that are contemplating a securities offering in the new year should consider submitting requests for acceleration or qualification as soon as practicable while the SEC remains open and operating. Our memo discusses what companies hoping to issue securities in early 2019 should do now.