What's New in the Division of Corporation Finance
November 2018

Compliance and Disclosure Interpretations

The following Compliance and Disclosure Interpretations (“C&DIs”) have been revised in light of the Commission’s recent changes to the “smaller reporting company,” “accelerated filer” and “large accelerated filer” definitions. In particular, we have updated Regulation S-K C&DIs 102.01, 102.02 and 202.01 and Exchange Act Forms C&DI 104.13 and withdrawn Exchange Act Rules C&DI 130.04 to reflect such amendments. We have also made non-substantive changes to Regulation S-K C&DI 146.09 and have withdrawn other outdated C&DIs indicated below.

• Exchange Act Rules (UPDATED 11/07/2018)
  • Questions 130.04, 169.01, 169.02, 169.03 withdrawn
• Regulation S-K (UPDATED 11/07/2018)
  • Updates to Questions 102.01, 102.02 and 202.01
  • Questions 110.01 and 133.09 withdrawn
• Exchange Act Forms (UPDATED 11/07/2018)
  • Update to Question 104.13

No-Action, Interpretive and Exemptive Letters

• Just Dial Limited, November 30, 2018
   
• Deutsche Access Investments Limited, November 20, 2018
   
• FSP 303 East Wacker Drive Corp. Liquidating Trust, November 13, 2018
   
• Brazilian Foreign Private Issuers, November 8, 2018
   
• Mphasis Limited, November 5, 2018
   
• International Stock Exchange Authority Limited, November 2, 2018