Cravath Publishes Winter 2026 Issue of Alumni Journal
Kimberley S. Drexler is a member of the Corporate Governance and Board Advisory Practice. Ms. Drexler has also spent significant time serving on the staff of the U.S. Securities and Exchange Commission in various capacities. Her current practice primarily involves counseling companies with regard to their ongoing SEC disclosure, financial reporting and compliance obligations, including preparing for and responding to cybersecurity incidents, as well as advising on a wide variety of matters critical to her clients relating to corporate governance, internal controls and auditor independence. She also provides advice with regard to the SEC’s disclosure requirements and the implications of the securities laws for complex corporate transactions.
Ms. Drexler returned to Cravath in 2007 as a senior attorney after serving as the Senior Advisor to the Director of the Division of Corporation Finance at the SEC from 2006 to 2007. During this period, she worked on a wide range of matters within the Division, spending considerable time on the SEC’s executive compensation disclosure rules and on the Commission’s efforts to improve the implementation of Section 404 of the Sarbanes‑Oxley Act of 2002, for which she received the Commission’s Law & Policy Award in 2007. She also worked on various other financial reporting issues and on international matters, including the Commission’s consideration of International Financial Reporting Standards (IFRS), as well as assisting with the Division’s efforts to update its interpretive guidance and to improve the transparency of the resources the Division provides to the public.
Ms. Drexler had previously served at the SEC in the Office of the General Counsel from 2000 to 2003, where she was a Senior Counsel and worked on a wide variety of Commission projects concerning financial reporting, including non‑GAAP financial measures, the increasing role of technology in the securities markets, and various other issues related to public company disclosures and capital raising. She served on the General Counsel’s team that advised on rulemakings under the Sarbanes‑Oxley Act, and she was awarded the Chairman’s Award for Excellence in conjunction with her work on the Commission’s auditor independence initiatives.
Ms. Drexler is actively involved with the national securities bar. From 2012 to 2015, she served as a Vice Chair of the Federal Regulation of Securities Committee of the Business Law Section of the American Bar Association. In August of 2017, Ms. Drexler was appointed by the President of the ABA to a three‑year term as a member of the National Conference of Lawyers and CPAs. She also served as the chair of the Public Company Reporting and Compliance Subcommittee (within the ABA’s Fed Reg Committee) from 2017 through 2021. Ms. Drexler is a Fellow of the American Bar Foundation.
Ms. Drexler has been recognized as a leading lawyer in securities regulation by Chambers USA and as among the “500 Global Leaders in Crisis Management” and “500 Leading Global Cyber Lawyers” by Lawdragon.
Ms. Drexler received a B.A. with highest distinction from the University of Virginia in 1993, where she was an Echols Scholar and was elected to Phi Beta Kappa, and a J.D. from Yale Law School in 1997, where she was a Coker Fellow and Managing Editor of the Yale Law & Policy Review.
Ms. Drexler joined Cravath in 1998, leaving for the SEC in 2000. She also worked at Cravath from 2004 to 2006. Ms. Drexler was elected a partner in 2022.
Ms. Drexler returned to Cravath in 2007 as a senior attorney after serving as the Senior Advisor to the Director of the Division of Corporation Finance at the SEC from 2006 to 2007. During this period, she worked on a wide range of matters within the Division, spending considerable time on the SEC’s executive compensation disclosure rules and on the Commission’s efforts to improve the implementation of Section 404 of the Sarbanes‑Oxley Act of 2002, for which she received the Commission’s Law & Policy Award in 2007. She also worked on various other financial reporting issues and on international matters, including the Commission’s consideration of International Financial Reporting Standards (IFRS), as well as assisting with the Division’s efforts to update its interpretive guidance and to improve the transparency of the resources the Division provides to the public.
Ms. Drexler had previously served at the SEC in the Office of the General Counsel from 2000 to 2003, where she was a Senior Counsel and worked on a wide variety of Commission projects concerning financial reporting, including non‑GAAP financial measures, the increasing role of technology in the securities markets, and various other issues related to public company disclosures and capital raising. She served on the General Counsel’s team that advised on rulemakings under the Sarbanes‑Oxley Act, and she was awarded the Chairman’s Award for Excellence in conjunction with her work on the Commission’s auditor independence initiatives.
Ms. Drexler is actively involved with the national securities bar. From 2012 to 2015, she served as a Vice Chair of the Federal Regulation of Securities Committee of the Business Law Section of the American Bar Association. In August of 2017, Ms. Drexler was appointed by the President of the ABA to a three‑year term as a member of the National Conference of Lawyers and CPAs. She also served as the chair of the Public Company Reporting and Compliance Subcommittee (within the ABA’s Fed Reg Committee) from 2017 through 2021. Ms. Drexler is a Fellow of the American Bar Foundation.
Ms. Drexler has been recognized as a leading lawyer in securities regulation by Chambers USA and as among the “500 Global Leaders in Crisis Management” and “500 Leading Global Cyber Lawyers” by Lawdragon.
Ms. Drexler received a B.A. with highest distinction from the University of Virginia in 1993, where she was an Echols Scholar and was elected to Phi Beta Kappa, and a J.D. from Yale Law School in 1997, where she was a Coker Fellow and Managing Editor of the Yale Law & Policy Review.
Ms. Drexler joined Cravath in 1998, leaving for the SEC in 2000. She also worked at Cravath from 2004 to 2006. Ms. Drexler was elected a partner in 2022.
Education
-
J.D., 1997, Yale Law SchoolCoker Fellow
-
B.A., 1993, University of VirginiaHighest Distinction, Echols Scholar, Phi Beta Kappa
Clerkships
- Hon. Victoria Lederberg, Rhode Island Supreme Court
Admitted In
- New York
Professional Affiliations
American Bar Association
- Federal Regulation of Securities Committee
- Corporate Governance Committee
- Law and Accounting Committee
American Bar Foundation
- Fellow
Rankings
Chambers USA
- Securities Regulation: Advisory - Nationwide (2025, 2024, 2023)
Lawdragon
- 500 Leading Dealmakers in America (2025)
- 500 Global Leaders in Crisis Management (2026, 2025)
- 500 Leading Global Cyber Lawyers (2025, 2024)
Law & Policy Award, U.S. Securities and Exchange Commission, 2007
Chairman’s Award for Excellence, U.S. Securities and Exchange Commission, 2000
Deals & Cases
February 24, 2026
ADT’s Acquisition of Origin
On February 24, 2026, ADT, a leading provider of security, interactive and smart home solutions serving residential and small business customers in the U.S., announced it has acquired Origin Wireless, Inc. (“Origin”), bringing Origin’s AI sensing platform and related intellectual property into the ADT ecosystem. The purchase price for the transaction was $170 million in cash, subject to customary purchase price adjustments. Cravath is representing ADT in connection with the transaction.
Deals & Cases
November 03, 2025
Kenvue’s $48.7 Billion Acquisition by Kimberly‑Clark
On November 3, 2025, Kenvue Inc. (“Kenvue”), a global consumer health leader, and Kimberly‑Clark Corporation (“Kimberly‑Clark”), a global personal care leader, announced an agreement under which Kimberly‑Clark will acquire all of the outstanding shares of Kenvue common stock in a cash and stock transaction that values Kenvue at an enterprise value of approximately $48.7 billion, based on the closing price of Kimberly‑Clark common stock on October 31, 2025. Under the terms of the agreement, which has been unanimously approved by each company’s Board of Directors, Kenvue shareholders will receive $3.50 per share in cash as well as 0.14625 Kimberly‑Clark shares for each Kenvue share held at closing. Upon closing of the transaction, current Kenvue shareholders are expected to own approximately 46% and current Kimberly‑Clark shareholders are expected to own approximately 54% of the combined company on a fully diluted basis. Cravath is representing Kenvue in connection with the transaction.
Deals & Cases
October 27, 2025
Alliance Laundry Holdings Inc.’s IPO
Cravath represented Alliance Laundry Holdings Inc. in connection with its $950.29 million initial public offering of common stock. Alliance Laundry Holdings, an affiliate of BDT & MSD Partners, LLC, is the world’s largest designer and manufacturer of commercial laundry systems, serving a diverse range of global markets. The transaction closed on October 10, 2025.
Deals & Cases
October 20, 2025
Banco Sabadell’s Defense Against BBVA’s Takeover Bid
On October 17, 2025, Banco Sabadell announced that the public takeover bid launched by BBVA in May 2024 received support from only 25.47% of shareholders, and therefore lapsed as it failed to reach the minimum acceptance threshold required for completion. Banco Sabadell will continue as an independent bank. Cravath is representing Banco Sabadell as U.S. counsel in connection with this matter.
Deals & Cases
October 01, 2025
Corteva’s Planned Separation into Two Public Companies
On October 1, 2025, global agricultural technology leader Corteva announced that its Board of Directors has unanimously approved a plan to separate the company into two independent, publicly traded companies, one comprising its current Crop Protection business (“New Corteva”) and the other comprising its current Seed business (“SpinCo”). 2025 net sales attributable to New Corteva are estimated to total $7.8 billion, representing 44% of net sales for Corteva; 2025 net sales attributable to SpinCo are estimated to total $9.9 billion, representing 56% of net sales for Corteva. The separation is expected to be effected through a spin‑off of SpinCo that is intended to qualify as a tax‑free transaction for U.S. federal tax purposes to Corteva shareholders. Cravath is representing Corteva in connection with the transaction.
Publications
March 11, 2026
FPI Section 16(a) Reporting Update: Final Rules, Conditional Exemptive Relief Order and Frequently Asked Questions
On March 11, 2026, Cravath prepared a memo for its clients entitled “FPI Section 16(a) Reporting Update: Final Rules, Conditional Exemptive Relief Order and Frequently Asked Questions.” The memo examines the U.S. Securities and Exchange Commission’s adoption of final rule and form amendments and issuance of a conditional exemptive relief order, as well as the Frequently Asked Questions posted by staff of the Division of Corporation Finance of the SEC, ahead of the March 18, 2026, deadline for compliance with the Holding Foreign Insiders Accountable Act.
Publications
November 24, 2025
SEC’s Division of Corporation Finance Significantly Reduces Staff’s Role in the Rule 14a‑8 Process for the 2025‑2026 Proxy Season
On November 21, 2025, Cravath prepared a memo for its clients entitled “SEC’s Division of Corporation Finance Significantly Reduces Staff’s Role in the Rule 14a‑8 Process for the 2025‑2026 Season.” The memo examines the Division of Corporation Finance’s (“CorpFin”) changes to the Rule 14a‑8 process for the 2025‑2026 proxy season that greatly reduce the staff’s role in the process.
Activities
October 22, 2025
John White and Kimberley Drexler Speak at Society for Corporate Governance’s 2025 Eastern Regional Conference
On October 20, 2025, Cravath partners John W. White and Kimberley S. Drexler participated in the Society for Corporate Governance’s 2025 Eastern Regional Conference, which was held from October 20‑21 in New York. The event featured a mix of panel discussions, interviews and networking sessions on topics such as generative AI, governance, regulatory and judicial developments, Delaware corporate law updates and geopolitical risk. Together, John and Kimberley led a fireside chat entitled “Under Pressure: Boardroom Leadership in a Shifting Landscape,” with a panel of public company directors that examined emerging trends and challenges in corporate governance and board practices, including how boards are navigating the political and social landscape and the implications for oversight, fiduciary responsibilities and stakeholder engagement. John also spoke on a panel of former senior Corporation Finance officers entitled “Regulatory Developments/SEC Panel,” which featured updates on the SEC and its Division of Corporation Finance and discussed evolving expectations around key areas of anticipated rulemaking to further the SEC’s mission, including disclosure rationalization, semi-annual reporting, shareholder proposals and shelf registration.
Activities
July 16, 2025
Kimberley Drexler Speaks at the Society for Corporate Governance’s 2025 National Conference
Cravath partner Kimberley S. Drexler participated in the Society for Corporate Governance’s 2025 National Conference, which was held from July 9‑12, 2025 in Colorado Springs. The program, entitled “Elevating Governance,” addressed challenges facing governance leaders through a combination of panels, keynotes, fireside chats and interactive roundtable sessions on topics including the corporate environment, core governance practices, key governance moments and the regulatory landscape. Kimberley spoke on a panel entitled “Taking a Fresh Look at Committee Structures,” in which panelists examined current demands and challenges, as well as evolving best practices, for board committees.
Publications
June 12, 2025
SEC Solicits Public Comment on the Eligibility Criteria for Foreign Private Issuer Status
On June 11, 2025, Cravath prepared a memo for its clients entitled “SEC Solicits Public Comment on the Eligibility Criteria for Foreign Private Issuer Status.” The memo examines a concept release recently published by the U.S. Securities and Exchange Commission to seek public comment on whether to revise the “foreign private issuer” definition in light of shifting trends in the characteristics of the FPI population.
Kimberley S. Drexler is a member of the Corporate Governance and Board Advisory Practice. Ms. Drexler has also spent significant time serving on the staff of the U.S. Securities and Exchange Commission in various capacities. Her current practice primarily involves counseling companies with regard to their ongoing SEC disclosure, financial reporting and compliance obligations, including preparing for and responding to cybersecurity incidents, as well as advising on a wide variety of matters critical to her clients relating to corporate governance, internal controls and auditor independence. She also provides advice with regard to the SEC’s disclosure requirements and the implications of the securities laws for complex corporate transactions.
Ms. Drexler returned to Cravath in 2007 as a senior attorney after serving as the Senior Advisor to the Director of the Division of Corporation Finance at the SEC from 2006 to 2007. During this period, she worked on a wide range of matters within the Division, spending considerable time on the SEC’s executive compensation disclosure rules and on the Commission’s efforts to improve the implementation of Section 404 of the Sarbanes‑Oxley Act of 2002, for which she received the Commission’s Law & Policy Award in 2007. She also worked on various other financial reporting issues and on international matters, including the Commission’s consideration of International Financial Reporting Standards (IFRS), as well as assisting with the Division’s efforts to update its interpretive guidance and to improve the transparency of the resources the Division provides to the public.
Ms. Drexler had previously served at the SEC in the Office of the General Counsel from 2000 to 2003, where she was a Senior Counsel and worked on a wide variety of Commission projects concerning financial reporting, including non‑GAAP financial measures, the increasing role of technology in the securities markets, and various other issues related to public company disclosures and capital raising. She served on the General Counsel’s team that advised on rulemakings under the Sarbanes‑Oxley Act, and she was awarded the Chairman’s Award for Excellence in conjunction with her work on the Commission’s auditor independence initiatives.
Ms. Drexler is actively involved with the national securities bar. From 2012 to 2015, she served as a Vice Chair of the Federal Regulation of Securities Committee of the Business Law Section of the American Bar Association. In August of 2017, Ms. Drexler was appointed by the President of the ABA to a three‑year term as a member of the National Conference of Lawyers and CPAs. She also served as the chair of the Public Company Reporting and Compliance Subcommittee (within the ABA’s Fed Reg Committee) from 2017 through 2021. Ms. Drexler is a Fellow of the American Bar Foundation.
Ms. Drexler has been recognized as a leading lawyer in securities regulation by Chambers USA and as among the “500 Global Leaders in Crisis Management” and “500 Leading Global Cyber Lawyers” by Lawdragon.
Ms. Drexler received a B.A. with highest distinction from the University of Virginia in 1993, where she was an Echols Scholar and was elected to Phi Beta Kappa, and a J.D. from Yale Law School in 1997, where she was a Coker Fellow and Managing Editor of the Yale Law & Policy Review.
Ms. Drexler joined Cravath in 1998, leaving for the SEC in 2000. She also worked at Cravath from 2004 to 2006. Ms. Drexler was elected a partner in 2022.
Ms. Drexler returned to Cravath in 2007 as a senior attorney after serving as the Senior Advisor to the Director of the Division of Corporation Finance at the SEC from 2006 to 2007. During this period, she worked on a wide range of matters within the Division, spending considerable time on the SEC’s executive compensation disclosure rules and on the Commission’s efforts to improve the implementation of Section 404 of the Sarbanes‑Oxley Act of 2002, for which she received the Commission’s Law & Policy Award in 2007. She also worked on various other financial reporting issues and on international matters, including the Commission’s consideration of International Financial Reporting Standards (IFRS), as well as assisting with the Division’s efforts to update its interpretive guidance and to improve the transparency of the resources the Division provides to the public.
Ms. Drexler had previously served at the SEC in the Office of the General Counsel from 2000 to 2003, where she was a Senior Counsel and worked on a wide variety of Commission projects concerning financial reporting, including non‑GAAP financial measures, the increasing role of technology in the securities markets, and various other issues related to public company disclosures and capital raising. She served on the General Counsel’s team that advised on rulemakings under the Sarbanes‑Oxley Act, and she was awarded the Chairman’s Award for Excellence in conjunction with her work on the Commission’s auditor independence initiatives.
Ms. Drexler is actively involved with the national securities bar. From 2012 to 2015, she served as a Vice Chair of the Federal Regulation of Securities Committee of the Business Law Section of the American Bar Association. In August of 2017, Ms. Drexler was appointed by the President of the ABA to a three‑year term as a member of the National Conference of Lawyers and CPAs. She also served as the chair of the Public Company Reporting and Compliance Subcommittee (within the ABA’s Fed Reg Committee) from 2017 through 2021. Ms. Drexler is a Fellow of the American Bar Foundation.
Ms. Drexler has been recognized as a leading lawyer in securities regulation by Chambers USA and as among the “500 Global Leaders in Crisis Management” and “500 Leading Global Cyber Lawyers” by Lawdragon.
Ms. Drexler received a B.A. with highest distinction from the University of Virginia in 1993, where she was an Echols Scholar and was elected to Phi Beta Kappa, and a J.D. from Yale Law School in 1997, where she was a Coker Fellow and Managing Editor of the Yale Law & Policy Review.
Ms. Drexler joined Cravath in 1998, leaving for the SEC in 2000. She also worked at Cravath from 2004 to 2006. Ms. Drexler was elected a partner in 2022.
Education
-
J.D., 1997, Yale Law SchoolCoker Fellow
-
B.A., 1993, University of VirginiaHighest Distinction, Echols Scholar, Phi Beta Kappa
Clerkships
- Hon. Victoria Lederberg, Rhode Island Supreme Court
Admitted In
- New York
Professional Affiliations
American Bar Association
- Federal Regulation of Securities Committee
- Corporate Governance Committee
- Law and Accounting Committee
American Bar Foundation
- Fellow
Rankings
Chambers USA
- Securities Regulation: Advisory - Nationwide (2025, 2024, 2023)
Lawdragon
- 500 Leading Dealmakers in America (2025)
- 500 Global Leaders in Crisis Management (2026, 2025)
- 500 Leading Global Cyber Lawyers (2025, 2024)
Law & Policy Award, U.S. Securities and Exchange Commission, 2007
Chairman’s Award for Excellence, U.S. Securities and Exchange Commission, 2000
Deals & Cases
February 24, 2026
ADT’s Acquisition of Origin
On February 24, 2026, ADT, a leading provider of security, interactive and smart home solutions serving residential and small business customers in the U.S., announced it has acquired Origin Wireless, Inc. (“Origin”), bringing Origin’s AI sensing platform and related intellectual property into the ADT ecosystem. The purchase price for the transaction was $170 million in cash, subject to customary purchase price adjustments. Cravath is representing ADT in connection with the transaction.
Deals & Cases
November 03, 2025
Kenvue’s $48.7 Billion Acquisition by Kimberly‑Clark
On November 3, 2025, Kenvue Inc. (“Kenvue”), a global consumer health leader, and Kimberly‑Clark Corporation (“Kimberly‑Clark”), a global personal care leader, announced an agreement under which Kimberly‑Clark will acquire all of the outstanding shares of Kenvue common stock in a cash and stock transaction that values Kenvue at an enterprise value of approximately $48.7 billion, based on the closing price of Kimberly‑Clark common stock on October 31, 2025. Under the terms of the agreement, which has been unanimously approved by each company’s Board of Directors, Kenvue shareholders will receive $3.50 per share in cash as well as 0.14625 Kimberly‑Clark shares for each Kenvue share held at closing. Upon closing of the transaction, current Kenvue shareholders are expected to own approximately 46% and current Kimberly‑Clark shareholders are expected to own approximately 54% of the combined company on a fully diluted basis. Cravath is representing Kenvue in connection with the transaction.
Deals & Cases
October 27, 2025
Alliance Laundry Holdings Inc.’s IPO
Cravath represented Alliance Laundry Holdings Inc. in connection with its $950.29 million initial public offering of common stock. Alliance Laundry Holdings, an affiliate of BDT & MSD Partners, LLC, is the world’s largest designer and manufacturer of commercial laundry systems, serving a diverse range of global markets. The transaction closed on October 10, 2025.
Deals & Cases
October 20, 2025
Banco Sabadell’s Defense Against BBVA’s Takeover Bid
On October 17, 2025, Banco Sabadell announced that the public takeover bid launched by BBVA in May 2024 received support from only 25.47% of shareholders, and therefore lapsed as it failed to reach the minimum acceptance threshold required for completion. Banco Sabadell will continue as an independent bank. Cravath is representing Banco Sabadell as U.S. counsel in connection with this matter.
Deals & Cases
October 01, 2025
Corteva’s Planned Separation into Two Public Companies
On October 1, 2025, global agricultural technology leader Corteva announced that its Board of Directors has unanimously approved a plan to separate the company into two independent, publicly traded companies, one comprising its current Crop Protection business (“New Corteva”) and the other comprising its current Seed business (“SpinCo”). 2025 net sales attributable to New Corteva are estimated to total $7.8 billion, representing 44% of net sales for Corteva; 2025 net sales attributable to SpinCo are estimated to total $9.9 billion, representing 56% of net sales for Corteva. The separation is expected to be effected through a spin‑off of SpinCo that is intended to qualify as a tax‑free transaction for U.S. federal tax purposes to Corteva shareholders. Cravath is representing Corteva in connection with the transaction.
Publications
March 11, 2026
FPI Section 16(a) Reporting Update: Final Rules, Conditional Exemptive Relief Order and Frequently Asked Questions
On March 11, 2026, Cravath prepared a memo for its clients entitled “FPI Section 16(a) Reporting Update: Final Rules, Conditional Exemptive Relief Order and Frequently Asked Questions.” The memo examines the U.S. Securities and Exchange Commission’s adoption of final rule and form amendments and issuance of a conditional exemptive relief order, as well as the Frequently Asked Questions posted by staff of the Division of Corporation Finance of the SEC, ahead of the March 18, 2026, deadline for compliance with the Holding Foreign Insiders Accountable Act.
Publications
November 24, 2025
SEC’s Division of Corporation Finance Significantly Reduces Staff’s Role in the Rule 14a‑8 Process for the 2025‑2026 Proxy Season
On November 21, 2025, Cravath prepared a memo for its clients entitled “SEC’s Division of Corporation Finance Significantly Reduces Staff’s Role in the Rule 14a‑8 Process for the 2025‑2026 Season.” The memo examines the Division of Corporation Finance’s (“CorpFin”) changes to the Rule 14a‑8 process for the 2025‑2026 proxy season that greatly reduce the staff’s role in the process.
Activities
October 22, 2025
John White and Kimberley Drexler Speak at Society for Corporate Governance’s 2025 Eastern Regional Conference
On October 20, 2025, Cravath partners John W. White and Kimberley S. Drexler participated in the Society for Corporate Governance’s 2025 Eastern Regional Conference, which was held from October 20‑21 in New York. The event featured a mix of panel discussions, interviews and networking sessions on topics such as generative AI, governance, regulatory and judicial developments, Delaware corporate law updates and geopolitical risk. Together, John and Kimberley led a fireside chat entitled “Under Pressure: Boardroom Leadership in a Shifting Landscape,” with a panel of public company directors that examined emerging trends and challenges in corporate governance and board practices, including how boards are navigating the political and social landscape and the implications for oversight, fiduciary responsibilities and stakeholder engagement. John also spoke on a panel of former senior Corporation Finance officers entitled “Regulatory Developments/SEC Panel,” which featured updates on the SEC and its Division of Corporation Finance and discussed evolving expectations around key areas of anticipated rulemaking to further the SEC’s mission, including disclosure rationalization, semi-annual reporting, shareholder proposals and shelf registration.
Activities
July 16, 2025
Kimberley Drexler Speaks at the Society for Corporate Governance’s 2025 National Conference
Cravath partner Kimberley S. Drexler participated in the Society for Corporate Governance’s 2025 National Conference, which was held from July 9‑12, 2025 in Colorado Springs. The program, entitled “Elevating Governance,” addressed challenges facing governance leaders through a combination of panels, keynotes, fireside chats and interactive roundtable sessions on topics including the corporate environment, core governance practices, key governance moments and the regulatory landscape. Kimberley spoke on a panel entitled “Taking a Fresh Look at Committee Structures,” in which panelists examined current demands and challenges, as well as evolving best practices, for board committees.
Publications
June 12, 2025
SEC Solicits Public Comment on the Eligibility Criteria for Foreign Private Issuer Status
On June 11, 2025, Cravath prepared a memo for its clients entitled “SEC Solicits Public Comment on the Eligibility Criteria for Foreign Private Issuer Status.” The memo examines a concept release recently published by the U.S. Securities and Exchange Commission to seek public comment on whether to revise the “foreign private issuer” definition in light of shifting trends in the characteristics of the FPI population.
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