As discussed in our Dec. 23, 2025, GT Alert and our March 9, 2026, GT Alert, Congress enacted the Holding Foreign Insiders Accountable Act (HFIAA), which extended Section 16(a) beneficial ownership reporting obligations under the Securities Exchange Act of 1934, as amended (Exchange Act) to directors and officers of foreign private issuers (FPIs), effective March 18, 2026.

The U.S. Securities and Exchange Commission (SEC) recognized that processing delays associated with the unusually large number of Form ID applications being submitted due to the HFIAA may contribute to FPIs failing to meet the March 18, 2026, deadline to comply with such Section 16(a) reporting requirements. Accordingly, the staff of the SEC’s Division of Corporate Finance (staff) released the below two FAQs on March 12, 2026, providing clarity and relief subject to certain conditions.

Click here to read the full GT Alert.

Tags: capital markets, GT Insight, SEC
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Photo of Raffael Fiumara Raffael Fiumara

Raffael Fiumara has wide-ranging corporate, capital markets, securities, and financing experience across over a decade in both private practice and in-house roles. Raffael focuses his practice on public and private equity and debt capital markets, SEC and stock exchange reporting, corporate governance and…

Raffael Fiumara has wide-ranging corporate, capital markets, securities, and financing experience across over a decade in both private practice and in-house roles. Raffael focuses his practice on public and private equity and debt capital markets, SEC and stock exchange reporting, corporate governance and compliance matters, corporate finance, mergers and acquisitions, and general corporate matters across a broad array of industries, including life sciences, fintech and financial services, technology, media, industrials, consumer, energy and natural resources.

Prior to joining Greenberg Traurig, Raffael served as vice president and senior counsel at Goldman Sachs for the Investment Banking Division, providing legal, policy, reputational, transactional and commercial advice on all aspects of the Investment Banking business.

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Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice

…

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including private and public financings, dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. She serves as a trusted advisor to public and private company boards of directors on governance matters and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and public and private companies in emerging technology, life sciences and biotechnology, defense and security, blockchain and digital assets, telecommunications, information technology, energy (traditional and renewable), mining, media, entertainment and sports. Barbara also represents Olympic and professional athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 1997 with Sullivan & Cromwell, LLP, and headed the international capital markets practice of Kirkland & Ellis LLP from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters, strategic alternatives, and digital asset structures. She serves on the Government of Bermuda’s Global FinTech Advisory Board.

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Photo of Marc M. Rossell Marc M. Rossell

Marc M. Rossell, co-chair of the firm’s Latin America Practice, focuses his practice on capital markets transactions, including both equity and debt securities offerings and structured financings. Marc has been involved in many of the largest securities offerings out of Latin America, including…

Marc M. Rossell, co-chair of the firm’s Latin America Practice, focuses his practice on capital markets transactions, including both equity and debt securities offerings and structured financings. Marc has been involved in many of the largest securities offerings out of Latin America, including landmark privatization offerings by the Argentine government’s national oil company and telephone companies, the privatization of the Peruvian telephone company, as well as many high-yield debt offerings and equity offerings of companies in Argentina, Chile, the Dominican Republic, Mexico, Panama, Peru and other countries. During the 1980s, he spent a considerable amount of time as bank advisory committee counsel, focusing on the restructuring of the external debt of many countries in Latin America. He also represents creditors and debtors in liability management transactions and has considerable experience with the issuance of project bonds to finance construction projects, many of which have won awards from industry publications.

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Photo of Almitra Gupta‡ Almitra Gupta‡

Almitra Gupta focuses on capital markets transactions and securities law. She represents issuers and underwriters in a variety of offerings, including liability management deals, shelf takedowns, medium-term note (MTN) and at-the-market (ATM) programs, and Rule 144A and other exempt offerings.

Almitra’s practice encompasses

…

Almitra Gupta focuses on capital markets transactions and securities law. She represents issuers and underwriters in a variety of offerings, including liability management deals, shelf takedowns, medium-term note (MTN) and at-the-market (ATM) programs, and Rule 144A and other exempt offerings.

Almitra’s practice encompasses drafting and negotiating key transaction documents, such as prospectuses, exchange offer and consent solicitation memoranda, and underwriting agreements. She advises clients on securities compliance and corporate governance matters, and assists with the preparation of proxy statements and periodic filings, including Forms 10-Q, 10-K, 20-F, 6-K, and 8-K.

In addition to her work with domestic clients, Almitra has international experience, having worked on capital market transactions while practicing in London, Singapore and India. She has been involved in notable deals, including the establishment of India’s first Infrastructure Investment Trust (InvIT) and advising on multiple social bond offerings.

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