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A New Era in Compensatory Equity Offerings?
Pillsbury Winthrop Shaw Pittman LLP 
[Guidance Overview] July 24, 2018
"The elimination of the comment period means that the SEC did not issue any guidance (transition or otherwise) on the practical implications of the amendment to Rule 701(e). However, the SEC's release provides that, if the effective date of the final rule ... occurs during an issuer's ongoing 12-month testing period, the issuer may rely on the increased $10 million disclosure threshold immediately."
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