How to Handle “Confidential Treatment Requests”

Our guest – White & Case’s Era Anagnosti – explains the “comment letter process” of the SEC’s Division of Corporation Finance, including:

1. What is eligible to be treated as “confidential information” and not disclosed in SEC filings?
2. If a company decides to redact an exhibit, how should the exhibit index for that company’s ’34 Act reports look like?
3. What is the screening process now for the Staff to decide whether to review a filing that has redacted information – that the Staff is conducting a compliance review of a company’s “confidential information” determination?
4. If the Staff asks to see an unredacted exhibit, how is that sent down to the Staff?
5. What is the process if the Staff decides to issue comments on a CTR? Oral or written? Timing?
6. How will a company know that it has responded to comments satisfactorily? That the review is now “closed”?
7. How about extensions of previously-granted requests – how does that work now?

For many more Vid-Guides dealing with corporate & securities law, corporate governance, E&S issues and more – particularly if you want to review any Vid-Guides referred to during this Vid-Guide – see the list of Vid-Guides spread throughout these categories:

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• Sustainability/E&S
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