On Wednesday, December 11, 2019, the NYSE resubmitted proposed rules to the SEC to enable capital raises through direct listings ("Primary Direct Listings"). Recall that the SEC rejected the NYSE's original proposed rules for Primary Direct Listings on December 6, 2019.

The NYSE's new proposed rules are substantially similar to the rules discussed in the December 4, 2019 edition of Momentum Minutes, except the new rules enable a company to meet the NYSE requirements for shares held by non-affiliates having a minimum aggregate value if (a) the company sells at least US$100 million (rather than US$250 million) in market value of shares in the opening auction on the first day of trading, or (b) based on the market value of the shares sold by the company in the opening auction on the first day of trading, such minimum aggregate value exceeds US$100 million.

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