Proposed Amendments to “Smaller Reporting Company” Definition: SEC’s Proposal Would Substantially Expand the Number of Registrants That Qualify as Smaller Reporting Companies

Sullivan & Cromwell LLP - July 29, 2016

The SEC has proposed amendments to the definition of “smaller reporting company” (SRC) as used in the SEC’s rules and regulations.  These amendments would substantially expand the number of registrants qualifying as SRCs by increasing the financial thresholds that registrants must meet to obtain SRC status.  Under the proposed rules, registrants with less than $250 million in public float (increased from $75 million) would qualify as SRCs, as would registrants with zero public float if their revenues were below $100 million in the previous year.