“On February 11, 2025, the staff of the SEC’s Division of Corporation Finance issued updated and new guidance regarding the eligibility of shareholders to file Schedule 13G instead of Schedule 13D beneficial ownership reports. The guidance notes that a shareholder’s ability to report on Schedule 13G depends on whether it holds the securities with a purpose or effect of “changing or influencing” control of the issuer.”

[COMMENTARY] This is a pertinent commentary on the recent US SEC changes to shareholder engagement.
Prepare for Changes to the Shareholder Engagement Process, by Brian V. Breheny, Raquel Fox, and Marc S. Gerber, March 11, 2025, Harvard Law School Forum on Corporate Governance, USA.