United States: Nasdaq's Blueprint To Revitalize U.S. Capital Markets

In what has proven to be a busy spring for various groups1 to assess the vitality of the financial markets, Nasdaq decided to join the fray as well. In early May, Nasdaq released its blueprint for revitalizing the U.S. capital markets by addressing several critically needed reforms with the hope that it sparks a dialogue – and action – among investors, public and private companies, industry groups, and policymakers.

Nasdaq's vision is rooted in the belief that robust public markets are the fuel that ignites America's economic engine and wealth creation. According to Nasdaq, companies list on U.S. stock exchanges to access a steady, dependable stream of capital to grow and create jobs, and investors choose our markets because they are the world's most trusted venues for long-term wealth creation. Unfortunately, however, Nasdaq believes that many companies are questioning whether the benefits of being a public company are worth the burdens after the U.S. has continued to add layer after layer of obligation. Nasdaq reports that, in recent years, a growing number of companies have chosen to remain private, and some public companies are deciding to stay private.

Nasdaq recognizes, however, that the market dynamics driving opposition to the public markets are complex. These include concerns about (1) shareholder activists, (2) frivolous shareholder litigation, (3) pressure to prioritize short-term returns over long-term strategic growth, and (4) burdensome costs and frustrations with the proxy process as well as onerous disclosure requirements, to name a few. Once public, companies – particularly smaller ones – sometimes find that the cost of accessing equity capital to fund growth can be expensive, given the distributed nature of trading across markets and trading venues today. Therefore, they seek private sources of capital, which, in today's environment, is abundantly available for many dynamic companies.

According to Nasdaq, the case for strong public markets is overwhelming. Since 1970, 92 percent of job creation has occurred after an IPO. Nasdaq notes that the vast majority of Americans are invested in and count on public markets, either directly through stock ownership or through pension funds, mutual funds and individual retirement accounts. Additionally, with more investors choosing index strategies to meet their investment needs, funds and exchange-traded product providers are relying upon a deep and healthy selection of public companies across industries and at various stages of maturity and growth to provide investors a wide range of index strategies with strong return profiles. Investor access to vibrant and growing public capital markets is a critical driver of wealth creation and financial security for the American people.

Today, pension funds are slowly shrinking and being replaced with defined contribution retirement plans (typically 401(k) plans) as the core savings vehicles for average American workers. Additionally, pension plans allocate only a small percentage of their overall portfolios to private alternative funds because the underlying investments are very illiquid and difficult to value. Defined contribution plans are even more limited in their ability to invest in private securities and private equity funds due to the lack of liquidity and valuation transparency. Therefore, for the foreseeable future, pension funds and most mutual funds serving average investors will continue to rely heavily on the public markets to supply investment opportunities that will help the funds reach their return thresholds. It will get harder and harder to achieve such return thresholds if there are fewer growth-oriented companies entering the public markets.

To address these concerns, Nasdaq provided concrete solutions across three topic areas in its blueprint:

For your convenience, a more detailed summary of each topic appears below.

Reconstructing the Regulatory Framework

Over time, an inconsistent regulatory patchwork has clearly developed that under-regulates some areas and over-regulates others. Public companies – and those contemplating an entrance into public markets – are increasingly hamstrung by the complexity and cost of navigating this regulatory maze, and investors are harmed by both the impact of these costs on companies that do go public and the shrinking investment options as more companies avoid going public.

A. Reform the Proxy Proposal Process

While proxy voting can be an important tool to raise legitimate concerns, Nasdaq believes it is far too often used for unhelpful purposes that cause a nuisance and significant financial strain on companies, particularly smaller ones. As a result, Nasdaq proposes a number of simple, commonsense reforms to protect the shareholder voice while filtering out needless and costly annoyances.

1. Raise the minimum ownership amount and holding period to ensure proposals have meaningful shareholder backing

Nasdaq suggests deleting the meaningless dollar threshold (currently $2,000) and instead require a proposing shareholder to hold at least 1 percent of the company's securities entitled to vote, and increase the holding period to three years. This would ensure that shareholder proposals representing the views of a meaningful percentage of a company's long-term owners are considered at shareholder meetings.

2. Update the SEC process for removing repetitive, unsuccessful proposals from proxies

Nasdaq believes Congress should significantly increase the shareholder support that a proxy proposal must receive before the same proposal can be reintroduced at future meetings. This concept was recently introduced in the Financial CHOICE Act of 2017. In addition, Nasdaq recommends that the SEC study the categories of topics suitable for shareholder proxies and modify its rules accordingly to ensure that proposals considered at annual meetings are properly placed before shareholders, are meaningful to the business of the company and are not related to ordinary business matters.

3. Create transparency and fairness in the proxy advisory industry

Nasdaq suggests that the SEC require proxy advisory firms to explain their criteria or provide companies a means to question analysis or even correct factual errors. In addition, these firms should be required to disclose whether they have a financial relationship or ownership stake in the companies on which they report.

B. Reduce the Burden of Corporate Disclosure

Nasdaq believes it is time to move away from a one-size-fits-all approach to corporate disclosure. Transparency is critical to healthy markets, but technology and markets have evolved to a point where a reasonable degree of flexibility can allow for disclosure requirements that are shareholder-friendly while reducing the burden on companies.

1. Offer flexibility on quarterly reporting

Nasdaq promotes amending the quarterly reporting process to provide for more flexibility. For example, Nasdaq believes that companies looking to encourage long-termism and reduce costs would benefit from the flexibility to provide full reports semiannually, as has been done in the United Kingdom. Under this approach, companies would be able to update key metrics for any material changes between mandated reports using existing disclosure methods.

2. Streamline quarterly reporting obligations for small- and medium-growth companies

As a practical matter, Nasdaq believes most investors view an earnings press release as a company's actual quarterly report on Form 10-Q. Yet, despite this view, companies are still required to file a more robust Form 10-Q with the SEC, which is complex, time-consuming, and provides little additional information that cannot be found in the earnings press release. By establishing simple guidelines, the earnings release can replace the Form 10-Q entirely for companies that prefer to report information quarterly, aligning regulatory and shareholder interests.

3. Expand classifications for disclosure relief

Current SEC rules permit certain types of companies, including emerging growth companies, smaller reporting companies and non-accelerated filers, to submit disclosure reports that are robust and transparent but far less burdensome than those required for more mature companies. However, few companies benefit from the spirit of these carve-outs because the definitions to qualify as an "emerging growth company," "smaller reporting company" or "non-accelerated filer" are narrow and, in some cases, limited in duration. Nasdaq believes the carve-outs should be expanded and simplified by:

  • Expanding the JOBS Act's "test the waters" provisions, allowing emerging growth companies to communicate with certain potential investors and file their registration statement confidentially, to all companies and all capital-raising transactions
  • Raising the revenue cap to qualify as an emerging growth company from the current $1 billion (subject to inflation adjustment every five years) to $1.5 billion
  • Deleting the current phaseout of emerging growth company status five years after such company's IPO
  • Harmonizing the definitions for "smaller reporting company" and "non-accelerated filer" with that of "emerging growth company" to avoid a patchwork of inconsistent and illogical exemptions

These suggestions dovetail with the SEC's Disclosure Effectiveness Initiative to simplify disclosure by stripping out unnecessary and duplicative requirements, thereby creating less onerous disclosure requirements for companies and more meaningful disclosure for investors. Similarly, Nasdaq believes that the SEC should consider ways to streamline the offering process by giving all public companies the opportunity to raise capital using simplified and faster "shelf registrations" and reducing the requirements for supplemental forms and other bureaucracy associated with capital raising that serve no meaningful purpose.

4. Roll back politically motivated disclosure requirements

Nasdaq believes there should be a clear distinction between disclosure of material information that investors require to evaluate a company's financial performance and economic prospects and those that are motivated by social and political causes or otherwise are not relevant to a company's bottom line. As such, Nasdaq supports the elimination of the currently required reporting of conflicts minerals and executive pay ratio, along with a comprehensive review of all disclosure requirements and the elimination of those that do not have a clear connection with a company's financial performance, practices and outlook.

C. Litigation Reform

The burden of having to defend meritless class action lawsuits is repeatedly cited by private companies as a major reason why they have not become public reporting companies. Given the trend of third-party investors financing these cases, Nasdaq expects that the number of cases filed will only increase, along with the burden placed on public companies, unless litigation reform is prioritized. The following sets forth the areas Nasdaq believes are necessary to reduce the burden of meritless class actions on public reporting companies.

1. Support legislation currently before Congress that addresses litigation reform

Nasdaq supports legislation reform that would, among other things, (1) ease the standard for imposing sanctions on lawyers bringing frivolous lawsuits, (2) tighten the requirements for granting class certification, (3) facilitate interlocutory appeal of decisions to grant class certification, (4) require disclosure of third-party financing of litigation and (5) limit plaintiff legal fees.

2. Expand the scope of provisions under congressional consideration

Nasdaq also encourages Congress to consider additional provisions that would (1) allow interlocutory appeals from the denial of a motion to dismiss; (2) allow a plaintiff to amend its complaint only once; (3) further codify the standards for pleading with respect to scienter and loss causation, and clarify the exclusive nature of federal jurisdiction over securities claims; (4) require proof of actual knowledge of material misstatements or omissions (as opposed to mere recklessness); and (5) make SEC findings in enforcement consent decrees inadmissible in private litigation.

3. Study longer-term comprehensive reform

Given the significant costs of the current litigation system and questions about whom the system actually benefits, Nasdaq advocates for more comprehensive changes.

D. Tax Reform

Finally, Nasdaq advocates for reform of U.S. tax policies that will promote, rather than discourage, saving and investment in the U.S. economy. Among other items, Nasdaq suggests expanding the tax exemption on the sale of small-business stock to the secondary market by revising Internal Revenue Code Section 1202 to include all qualified domestic corporations. Nasdaq also recommends shortening the ownership tenure requirement from five years to three years, and increasing the maximum asset threshold from $50 million to $100 million. Nasdaq believes this shareholder-friendly move would enable smaller companies to access the public markets. In addition, Nasdaq supports complete elimination of the double taxation of corporate profits through a 100 percent dividends received deduction for holders of qualified domestic corporate stock.

Modernizing Financial Market Structure

Nasdaq believes that the fundamental structure that underpins our financial markets has not evolved to benefit all market segments equally. Accordingly, while efficient markets benefit both issuers and investors, inefficient markets can choke the flow of capital, become a drain on growth and block companies – particularly small- and medium-growth companies – from reaching their fullest potential. As such, Nasdaq proposes new and improved frameworks that account for the different needs among market participants and the fluid nature of our markets.

A. Strengthen Markets for Smaller Companies

Nasdaq believes concentrating disaggregated liquidity onto a single stock exchange, with limited exceptions, will allow investors to better source liquidity, increase price transparency, and result in less dramatic price swings for small- and medium-growth companies and their investors.

B. Give Companies a Choice to Consolidate Liquidity and Improve Trading Quality

By creating a market for smaller companies that is voluntary for companies to join and that is largely exempt from the unlisted trading privileges (UTP) obligations, subject to key exclusions, Nasdaq can concentrate liquidity to reduce volatility and improve the trading experience. Eliminating UTP for small- and medium-growth companies would reduce the number of exchanges authorized to trade them, and, more important, it would allow for liquidity to develop and for supply and demand to find one another.

In addition, Nasdaq proposes the following changes: (1) deploy intelligent tick sizes for small- and medium-growth companies, (2) cultivate innovative market-level solutions that improve the trading of small- and medium-growth companies, (3) implement an intelligent rebate/fee structure that promotes liquidity and avoids market distortions, and (4) ensure fair and reasonable pricing for participants in the context of limiting exchange competition.

Promoting Long-Term Views of Value Creation

Nasdaq believes that in recent years, a variety of market dynamics have started to disfavor long-term investors and long-term corporate strategies. Market participants and the investing community have become less patient with corporate management and boards of directors, as well as their overarching strategies to deliver shareholder returns.

This results in private companies being forced to weigh the capital-raising benefits of public markets with the risks that they will be unable to pursue productive long-term strategies. The trend away from long-term thinking is also harmful to investors with long-term outlooks and to the broader American economy because sustained job creation and economic output depend on a company's ability to measure performance not in quarters or fiscal years but in decades.

In particular, Nasdaq advocates for reforms that help public companies plan and execute for long-term growth, job creation and innovation, and ensure that long-term investors have an equal opportunity to participate in wealth creation with those investors who focus on speed and market timing.

A. Industry Dialogue to Address Concerns Regarding Activist Investors

There are many dimensions to the issue of activist investing, and Nasdaq is a strong believer in the capital markets ecosystem, exchanges, issuers and investors coming together to develop a comprehensive solution to this concern. For instance, Nasdaq strongly supports, and has built into its listing standards, the need for greater transparency around arrangements by which activist investors tie director compensation to a company's stock price, which creates the potential for conflicts between the activist's and the company's best interest. Nasdaq is a firm believer that this dialogue should focus on several key issues that promote transparency so that investors and activists are on a level playing field when engaging with a company.

B. Equalize Short Interest Transparency

U.S. securities laws require certain investors to disclose their long positions 45 days after the end of each quarter and require institutions to make disclosure within 10 days after their position reaches or exceeds 5 percent of a company's outstanding shares. As has been hotly debated among practitioners, there are no corresponding disclosure requirements applicable to short positions. Nasdaq believes that legitimate short selling contributes to efficient price formation, enhances liquidity and facilitates risk management. Short sellers may benefit the market and investors in other important ways, including by identifying and uncovering instances of fraud and other misconduct at public companies.

To provide transparency to other investors and the affected companies, Nasdaq supports extending existing disclosure requirements for long investors, such as on Form 13F, Schedule 13D and Schedule 13G, to persons with short positions, including any agreements and understandings that allow an investor to profit from a loss in value of the subject security.

C. Continue to Support Dual Class Structures

Nasdaq supports dual class structures in appropriate situations. The U.S. is a hotbed for entrepreneurship and innovation, and in order to maintain this strength, we must offer entrepreneurs multiple paths to participate in public markets. Nasdaq believes that by permitting dual class structures investors can invest side by side with innovators and high-growth companies and enjoy the financial benefits of these companies' success. Consistent with its one-size-does-not-fit-all approach, Nasdaq believes each publicly traded company should have the flexibility to determine its class structure, so long as the company is transparent and initially discloses such structure to investors.

D. Encourage Rather Than Mandate Environmental, Social and Governance (ESG) Disclosure

As stated in its blueprint, most of Nasdaq's listed companies make some ESG disclosures not only because they believe in responsible business practices but also because they understand that investors are increasingly expecting to analyze ESG metrics in their decision-making process. In keeping with its one-size-does-not-fit-all approach, Nasdaq generally supports the principle that ESG reporting should not be mandated but instead encouraged, so that companies can determine on a case-by-case basis how best to address ESG disclosures and so that the disclosures remain valuable to investors.


While Nasdaq's blueprint does provide some interesting ideas and is meant to foster dialogue between industry participants, it does acknowledge that comprehensive market reform is extraordinarily complex. Indeed, most recognize that a variety of factors have likely contributed to making it more difficult or less attractive for smaller companies to go public.

There is certainly no shortage of suggested causes or possibilities, including the availability of alternative sources of capital, including private equity, hedge funds and even mutual funds; the emergence of trading venues that provide liquidity for privately held shares; new offering methods, such as crowdfunding, and Regulation A; consolidation in investment banking and brokerage services, which left fewer underwriters for small IPOs; changes in the economic environment due to globalization; industry trends forcing companies to get bigger faster to improve profitability, and therefore prefer being acquired by a large company instead of growing organically; macroeconomic factors, such as cheaper debt financing and increased mergers and acquisitions activity; high costs disproportionately imposed on smaller companies by regulatory changes from Sarbanes-Oxley; decimalization and Regulation NMS changed the economics of market making for small company stocks and left fewer market makers willing to organize a market for small stocks post-IPO; an increase in the shareholder threshold introduced by the JOBS Act in 2012, also make it more likely that companies will stay private for a longer period of time; and a significant shift away from retail investing toward institutional investing ‒ who have little interest in investing in small-cap public companies because of concerns regarding trade liquidity and regulatory barriers. Although much of the focus has been placed on reinvigorating the IPO market, there are certainly other areas of the securities laws that are ripe for change as well, which would also have a positive impact on the financial markets. Regardless, we need to bring a balanced approach to study both demand-side and supply-side reforms in order to attract more companies to the public markets.


1 See Committee on Capital Markets Regulation, "U.S. Public Equity Markets Are Stagnating," April 2017; Committee on Capital Markets Regulation, "Roadmap for Regulatory Reform," May 2017; SEC Commissioner Piwowar's Opening Remarks in May 2017 at the SEC-NYU Dialogue on Securities Market Regulation: Reviving the U.S. IPO Market; Ernst & Young's "Looking Behind the Declining Numbers of Public Companies – An Analysis of Trends in U.S. Capital Markets," May 2017; and SEC Investor Advocate Rick Fleming, "Enhancing the Demand for IPOs," May 2017, NASAA 2017 Public Policy Conference.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:
  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.
  • Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.
    If you do not want us to provide your name and email address you may opt out by clicking here
    If you do not wish to receive any future announcements of products and services offered by Mondaq you may opt out by clicking here

    Terms & Conditions and Privacy Statement

    Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

    Use of www.mondaq.com

    You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


    Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

    The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


    Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

    • To allow you to personalize the Mondaq websites you are visiting.
    • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
    • To produce demographic feedback for our information providers who provide information free for your use.

    Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

    Information Collection and Use

    We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

    We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

    Mondaq News Alerts

    In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


    A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

    Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

    Log Files

    We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


    This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

    Surveys & Contests

    From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


    If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


    From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

    *** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .


    This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

    Correcting/Updating Personal Information

    If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

    Notification of Changes

    If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

    How to contact Mondaq

    You can contact us with comments or queries at enquiries@mondaq.com.

    If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.

    By clicking Register you state you have read and agree to our Terms and Conditions