Key takeaways

• Beginning on July 10, 2017, all issuers will have the option to submit for nonpublic review by the Securities and Exchange Commission registration statements and related amendments for IPOs or spin-offs, as well as subsequent initial registration statement filings during the 12 months following an IPO.
• Confidential submission and review of registration statements, a popular JOBS Act benefit, was previously available only to Emerging Growth Companies (“EGCs”). With this change, non-EGCs will now have greater flexibility when planning an IPO or subsequent registered securities offering. 
• The SEC’s new confidential submission procedures do not affect JOBS Act benefits currently available to EGCs or make any other JOBS Act benefits available to non-EGCs.