On December 6, 2019, the U.S. Securities and Exchange Commission rejected a proposed New York Stock Exchange ("NYSE") rule change that would allow companies to raise capital in a direct listing and, subject to satisfaction of additional valuation requirements, provide a 90-day grace period for the requirement to have 400 round lot holders. The NYSE has indicated that it intends to revise and resubmit the proposal. The Nasdaq Stock Market is also working on a proposal to permit capital raising in direct listings. For additional information, see our prior Commentary on the NYSE proposal.
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