Proposed Regulatory Changes to Permit Certain Exchange Offer Registration Statements

SIFMA provides comments to the Securities and Exchange Commission (SEC) proposing regulatory changes to permit certain exchange offer registration statements of “well known seasoned issuers” (WKSI). In order to facilitate exchange offers being conducted on a registered basis to all security holders, we propose that registration statements on Form S-4 filed by WKSI become effective immediately upon filing of the registration statement on Forms S-4 or F-4 in the same way that WKSI registration statements on Forms S-3 and F-3 now go effective immediately.