On March 16, 2026, the Securities and Exchange Commission (SEC) proposed amendments to Exchange Act Rule 15c2-11 that formally limit the rule’s scope to equity securities. The proposal carries significant practical implications for broker-dealers, fixed-income issuers, and capital markets participants alike after years of regulatory uncertainty.

Although the March 18, 2026 deadline for directors and officers of foreign private issuers (FPIs) to file their initial Form 3 and other required Section 16(a) reports with the SEC under the Holding Foreign Insiders Accountable Act (HFIAA) has now passed, the SEC staff has provided additional no-action relief with respect to compliance with the filing requirements for insiders of FPIs that are headquartered or organized in Israel or any other jurisdiction in the region directly impacted by the ongoing military conflict with Iran.