Posts by Timothy HoPartner
Beginning March 18, 2026, directors and officers[1] of foreign private issuers, or FPIs, must report their beneficial ownership of, and their transactions involving, an FPI’s securities under Section 16(a) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”).
The wires have hit. You’ve just closed a multijurisdictional offering and delivered a great result for your client. As visions of a raucous post-closing party with your client enter your mind (or perhaps just visions of a good night’s sleep!), U.S. counsel interrupts your reverie with a reminder that your client’s Form D and associated blue sky filings are due within 15 days. Say what? Do you really have to make these filings, and what in the world are “blue sky laws” anyway? Although not quite as colorful and catchy as a Jimi Hendrix song, blue sky laws can leave you in a purple haze if not carefully considered. Let’s explore this often-overlooked topic in further detail.