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In 2021, the SEC clarified that amended Rule 15c2-11 would apply to debt securities issued in private offerings pursuant to Rule 144A and Regulation S under the Securities Act of 1933, in addition to equity securities, thus expanding the number of companies that could be compelled to publicly disclose current
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SEC Grants Exemptive Relief From Rule 15c2-11 Disclosure Requirements

https://www.stblaw.com/about-us/publications/view/2023/11/01/sec-grants-exemptive-relief-from-rule-15c2-11-disclosure-requirements-for-rule-144a-fixed-income-securities
In 2021, the SEC clarified that amended Rule 15c2-11 would apply to debt securities issued in private offerings pursuant to Rule 144A and Regulation S under the Securities Act of 1933, in addition to equity securities, thus expanding the number of companies that could be compelled to publicly disclose current