SEC Publishes New CD&I On Schedule 13D-G
In October 2023, the SEC adopted final amendments to Sections 13(d) and 13(g) of the Exchange Act. To review the final amendments see HERE and HERE. In March 2025, the SEC published a few CD&I’s related to the new amendments (see HERE).
The amendments updated Sections 13(d), 13(g) and Regulation 13D-G to accelerate filing deadlines for both initial and amended reports; expand the timeframe within a business day in which filings may be timely made; clarify the Schedule 13D disclosure requirements with respect to derivative securities; and require that Schedule 13D and 13G filings be filed using XBRL.
On July 11, 2025, the SEC published 18 revised CD&Is on the filing of Schedules 13D and 13G. Many of the changes are clean-up, clarification and updates to align the guidance with the October 2023 amendments.
Section 13(d)
Two of the revised CD&I address Section 13(d) of the Exchange Act.
Revised CD&Is 101.01 and 103.01 confirm that when a company
