Cravath Publishes Two Memos on SEC’s Proposed Filer Status and Registered Offering Reforms and Request for Comment on IPO Modernization

On June 15, 2026, Cravath prepared two companion memos for its clients entitled “The Bold and the Creative (Part I): SEC Proposes to Rationalize Filer Status Framework and Extend Accommodations to Significantly More Registrants” and “The Bold and the Creative (Part II): SEC Proposes Significant Registered Offering Reforms Designed to Incentivize Companies to Go and Stay Public and Seeks Public Comment on Further Modernization.” 

Part I of the memo examines the SEC’s proposed rule amendments to rationalize its existing filer status framework and extend scaled disclosures and other accommodations to many registrants. Part II of the memo examines proposed rule amendments to reform registered offerings by making certain existing accommodations more broadly available and discusses SEC Chairman Paul Atkin’s request for public comment on the modernization of the initial public offering process and related rules. 

Please click here to read Part I of the memo.

Please click here to read Part II of the memo.