The SEC has issued a significant exemptive order modernizing and expanding the ability of issuers to conduct tender offers for their non-convertible debt securities over an abbreviated period of five business days. This new exemptive order expressly supersedes previous guidance contained in the 2015 no-action letter, often referred to as the Abbreviated Debt Tender Offer Letter, and introduces greater flexibility and efficiency for liability management transactions, including the ability to conduct partial tender and exchange offers, conduct exchange offers without an accompanying retail tender offer, and couple typical consent solicitations with an offer. This pragmatic shift recognizes current market realities and technological advancements, and continues the trend established by the SEC’s April 2026 exemptive order for equity tender offers (which permitted a minimum 10 business day offering period for certain equity tender offers), offering a more robust framework for managing outstanding debt.
Continue Reading SEC Modernizes Debt Tender Offer Rules with New Exemptive OrderLesley Janzen
SEC Reduces Minimum Equity Tender Offer Period to 10 Business Days
The Securities and Exchange Commission recently cut the minimum time required for certain equity tender offers in half. Historically, federal rules mandated that such offers remain open for at least 20 business days. Now, an April 16, 2026 exemptive order from the Division of Corporation Finance allows market participants to conclude qualifying cash tender offers in just 10 business days. While this new relief applies exclusively to equity securities, it signals a pragmatic shift at the SEC and suggests market participants may see similar relief formalized for debt tender offers down the road.
Continue Reading SEC Reduces Minimum Equity Tender Offer Period to 10 Business DaysGlobal IPO Market Trends: 2025 Review and 2026 Outlook
The following is part of our annual publication Selected Issues for Boards of Directors in 2026. Explore all topics or download the PDF.
Drawing on activity across the United States, Europe, East Asia, the Middle East and Latin America, we examine the market dynamics and complimentary regulatory and macro-economic settings that drove IPO volume and valuations to surge in 2025 and offer insights for the year ahead.
Continue Reading Global IPO Market Trends: 2025 Review and 2026 Outlook