SEC releases sample letter to companies regarding China-specific disclosures

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Jul 18, 2023

On July 18, 2023, the Securities and Exchange Commission (SEC) posted a sample comment letter regarding the disclosure obligations of companies based in or with a majority of their operations in the People’s Republic of China.

The explanation notes that Division of Corporation Finance is focused on the following three key areas of disclosure regarding China-specific matters:

  • Disclosure obligations under the Holding Foreign Companies Accountable Act
  • “Specific and prominent disclosure” about material risks related to the role of the government of the People’s Republic of China in the operations of China-based companies
  • Disclosures regarding the material impacts of certain statutes including, for example, the Uyghur Forced Labor Prevention Act (UFLPA)

Re­view the comment letter on SEC’s website.

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