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Cooley says it obtained SEC staff guidance for Sumisho Air Lease
Cooley said it obtained SEC staff interpretive guidance for client Sumisho Air Lease concerning continued Form S-3 eligibility during a temporary voluntary reporting period. The firm said the guidance extended the Lamar Advertising framework to recognize a mandatory shelf update as another route back to required reporting.
Key points
- Cooley said the staff issued its guidance on October 26.Cooley
- The firm said Sumisho’s reporting obligation was expected to be suspended on January 1, 2027.Cooley
- Cooley said the voluntary period could last approximately three months before filing the 2026 Form 10-K.Cooley
- The firm said the staff revised Securities Act Forms CFI Question 115.15 to cite the letter.Cooley