Firm Submits Comments on SEC's Proposal to Amend Rules Relating to Foreign Private Issuers

Robert C. Mangone submitted comments to the SEC on January 18, 2006 responding to the Commission's request for comments on its proposal to ease the rules allowing a foreign private issuer to terminate its registration of securities under Section 12(g) of the Securities Exchange Act of 1934 and thereby stop filing reports required of registered companies.

Mr. Mangone stated that our Firm fully concurs in the Commission's objective to give foreign private issuers stronger incentives to enter into our Exchange Act reporting system by lowering the costs and other obstacles of exiting from that system. He agreed that the proposed rules would benefit investors, because they remove a disincentive for such foreign companies to register their securities with the Commission by lessening their concerns that the reporting system is difficult to leave once a company enters it. Among other things, he suggested that the present 300-shareholder threshold for withdrawing from registration is no longer reasonable. Click here to see the full text of the comment letter.