Self-Regulatory Organizations; New York Stock Exchange, Inc.; Order Approving Proposed Rule Change and Amendment No. 3 Thereto Relating to Procedures for Companies That Fail To File Annual Reports in a Timely Manner, 33573-33575 [E5-2938]
Download as PDF
Federal Register / Vol. 70, No. 109 / Wednesday, June 8, 2005 / Notices
For the Commission, by the Division of
Market Regulation, pursuant to delegated
authority.9
Margaret H. McFarland,
Deputy Secretary.
[FR Doc. E5–2933 Filed 6–7–05; 8:45 am]
The Commission received two comment
letters regarding the proposed rule
change.8 On March 1, 2005, the
Exchange submitted a response to the
comments.9 This order approves the
proposed rule change, as amended.
BILLING CODE 8010–01–P
II. Description of the Proposed Rule
Change
The Exchange is proposing to codify
existing procedures followed where
companies fail to satisfy the
Commission’s filing requirements for
annual reports on Forms 10–K, 10–KSB,
20–F, 40–F, or N–CSR in a timely
manner. The proposed rule change
would apply with full effect to
companies that are already late in filing
their annual report on Form 10–K, 20–
F, 40–F, or N–CSR with the SEC as of
the date that the Commission approves
this rule filing.10 Specifically, a
company that fails to file its annual
report with the Commission in a timely
manner would be subject to the
following procedures under new
Paragraph 802.01E of the Listed
Company Manual:
Under Paragraph 802.01E, once the
Exchange identifies that a company has
failed to file a timely periodic annual
report with the Commission by the later
of (a) the date that the annual report was
required to be filed with the
Commission by the applicable form or
(b) if a Form 12b–25 was timely filed
with the Commission, the extended
filing due date for the annual report, the
Exchange would notify the company in
writing of its status. The later of these
two dates would be referred to as the
‘‘Filing Due Date.’’
Within five days of receipt of this
notification, the company would be
required to (a) contact the Exchange to
discuss the status of the annual report
filing, and (b) if it has not already done
so, issue a press release disclosing the
status of the filing. If the company failed
to issue this press release in a timely
manner, the Exchange would itself issue
a press release stating that the company
has failed to timely file its annual report
with the Commission.
During the nine-month period from
the Filing Due Date, the Exchange
would monitor the company and the
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–51777; File No. SR–NYSE–
2004–49]
Self-Regulatory Organizations; New
York Stock Exchange, Inc.; Order
Approving Proposed Rule Change and
Amendment No. 3 Thereto Relating to
Procedures for Companies That Fail To
File Annual Reports in a Timely
Manner
June 2, 2005.
I. Introduction
On August 19, 2004, the New York
Stock Exchange, Inc. (‘‘NYSE’’ or
‘‘Exchange’’) submitted to the Securities
and Exchange Commission
(‘‘Commission’’ or ‘‘SEC’’), pursuant to
Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change codifying existing procedures
followed where companies fail to satisfy
the Commission’s filing requirements
for annual reports on Forms 10–K, 10–
KSB, 20–F, 40–F, or N–CSR in a timely
manner. The proposed rule change was
published for public comment in the
Federal Register on October 1, 2004.3
The Exchange filed Amendments No. 1 4
and 2 5 on October 29, 2004 and
November 29, 2004, respectively. On
December 21, 2004, the Exchange filed
Amendment No. 3 to the proposed rule
change.6 Amendment No. 3 was
published for public comment in the
Federal Register on January 14, 2005.7
9 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 Securities Exchange Act Release No. 50452
(September 27, 2004), 69 FR 58987.
4 See letter from Mary Yeager, Assistant Secretary,
NYSE, to Nancy J. Sanow, Assistant Director,
Division of Market Regulation, Commission, dated
October 28, 2004 (‘‘Amendment No. 1’’).
5 Amendment No. 2 replaced and superseded
Amendment No. 1. On December 21, 2004, the
Exchange withdrew Amendment No. 2.
6 Amendment No. 3 clarified that the proposed
rule change would apply to companies that are
already late in filing their annual reports as of the
date that the Commission approves the proposed
rule change.
7 Securities Exchange Act Release No. 50982
(January 6, 2005), 70 FR 2686. Amendment No. 3
clarified that the proposed rule change would apply
to companies that are already late in filing their
annual reports as of the date that the Commission
approves the proposed rule change.
1 15
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18:08 Jun 07, 2005
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8 See letters from James J. Angel, Associate
Professor of Finance, McDonough School of
Business, Georgetown University (‘‘Angel’’), to
Jonathan G. Katz, Secretary, Commission (‘‘Angel
Letter’’), and Edward S. Knight, Executive Vice
President and General Counsel, The Nasdaq Stock
Market, Inc. (‘‘Nasdaq’’), to Jonathan G. Katz,
Secretary, Commission, dated February 4, 2005
(‘‘Nasdaq Letter’’).
9 See letter from Mary Yaeger, Assistant Secretary,
NYSE, to Sharon Lawson, Division of Market
Regulation, Commission, dated March 1, 2005.
10 See Amendment No. 3, supra note 6.
PO 00000
Frm 00133
Fmt 4703
Sfmt 4703
33573
status of the filing, including through
contact with the company, until the
annual report is filed. Under the
procedure, if the company failed to file
the annual report within nine months
from the Filing Due Date, the Exchange
would be permitted, in its sole
discretion, to allow the company’s
securities to be traded for up to an
additional three-month trading period
depending on the company’s specific
circumstances. If the Exchange
determined that an additional trading
period of up to three months is not
appropriate, suspension and delisting
procedures would commence in
accordance with the procedures set out
in Paragraph 804.00 of the Listed
Company Manual.11 The new rule
specifically states that a company would
not be eligible to follow the procedures
outlined in Paragraphs 802.02 and
802.03 with respect to this criteria.12
In determining whether an additional
trading period of up to three-months is
appropriate, the rule specifically states
that the Exchange would consider the
likelihood that the filing could be made
during the additional period, as well as
the company’s general financial status,
based on information provided by a
variety of sources, including the
company, its audit committee, its
outside auditors, the staff of the
Commission and any other regulatory
body. The new procedures also state
that the Exchange strongly encourages
companies to provide ongoing
disclosure on the status of the annual
report filing to the market through press
releases, and that the Exchange will take
the frequency and detail of such
information into account in determining
whether an additional three-month
trading period is appropriate. If the
Exchange determined that an additional,
up to three-month trading period was
appropriate and the company failed to
file its periodic annual report by the end
of the additional period, suspension and
delisting procedures would commence
in accordance with the procedures set
out in Paragraph 804.00 of the Listed
Company Manual.13
11 Paragraph 804 sets forth the procedures the
Exchange follows when it determines a security
should be delisted, and the issuer’s right of review
of such decisions.
12 Paragraphs 802.02 and 802.03 provide
generally, among other things, that when a listed
company is not in compliance with the Exchange’s
continued listing criteria, the Exchange notifies the
company of its status and the company is given the
opportunity to provide a plan advising the
Exchange of the definitive action the company
intends to take that would bring it into conformity
with continued listing standards.
13 See also supra notes 11 and 12. In such a case,
the procedures of Paragraphs 802.02 and 802.03
would not be available, as discussed above.
E:\FR\FM\08JNN1.SGM
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Federal Register / Vol. 70, No. 109 / Wednesday, June 8, 2005 / Notices
The Commission notes that new
Paragraph 802.01E permits the
Exchange to suspend trading
immediately and commence delisting
procedures for a late annual report filer
in accordance with Paragraph 804.
Specifically, the new rule states that if,
at any time, the Exchange deemed it
necessary or appropriate in the public
interest or for the protection of
investors, trading in any security could
be suspended immediately, and, in
accordance with the procedures set out
in Paragraph 804.00, application made
to the Commission to delist the security.
III. Comments
The Commission received a total of
two comment letters: the Nasdaq Letter
and the Angel Letter,14 and a response
from the NYSE.15 Angel stated that the
proposal seemed reasonable overall, but
that the NYSE should place an indicator
on the ticker symbol of companies that
are late in making required filings with
the SEC. The Angel Letter also noted
that Nasdaq puts an ‘‘E’’ on the end of
a ticker symbol of companies late in
required Commission filings and that
the same identifier should be seen on
NYSE late filers. Angel also
recommended expanding the scope of
the proposal to companies that are late
in filing their quarterly reports, noting
that this is just as important, if not more
so, than late filers of annual reports.
Nasdaq stated that the proposal does
not ‘‘go nearly far enough to protect
investors.’’ Nasdaq also stated that it
does ‘‘not believe that a market should
offer what is essentially a blanket nine
months filing extension to delinquent
issuers’’ and that ‘‘the NYSE should be
required to adopt a more reasonable
timeframe to respond to annual report
filing delinquencies.’’ In support of this,
Nasdaq notes that the issuer’s financial
statements would be at least a year old
at the end of NYSE’s nine month period.
In addition, Nasdaq stated that quarterly
reports are an important element of
information which is available to
investors and that without current
financials, it is impossible for a
marketplace to determine whether a
listed issuer complies with continued
listing standards. Further, Nasdaq noted
that its own procedures cover late
annual and interim reports and if an
issuer fails to timely file required
reports it is promptly notified it will be
delisted unless it appeals.16
14 See
supra note 8.
supra note 9.
16 Nasdaq further stated that appeal hearings with
respect to filing delinquencies are scheduled on an
expedited basis and generally occur within three
weeks.
15 See
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18:08 Jun 07, 2005
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In response to these comments, the
NYSE stated that it agrees that investors
should be provided with timely notice
of companies that fail to file annual
reports on time.17 The NYSE further
stated that ‘‘since July 2004, the
Exchange has monitored and
disseminated transparent information
on companies that fail to satisfy the
Commission’s requirement to file their
annual financials in a timely manner.’’
The NYSE further stated that it
‘‘appends an ‘.LF’ indicator in the
financial status field of the company’s
ticker symbol and distributes that
information via the low speed ticker and
through [its] data stream to market
vendors.’’ The Exchange also stated that
it keeps an updated list of companies
that are late in their filings on its
website, and notes the late filing status
on the company’s data page on its Web
site. In response to Angel’s and
Nasdaq’s recommendation of identifying
and expanding the scope of the proposal
to companies that are late in filing their
quarterly reports, the NYSE stated that
it is currently involved in conversations
with the Commission regarding the
identification of companies that have
failed to timely file quarterly reports.
The NYSE also noted that to the extent
a company files an overdue annual
report, the NYSE will not remove the
.LF indicator or the company’s late
filing status on its website until such
time as all outstanding interim reports
are up to date. In response to Nasdaq’s
comment that the proposal would give
a blanket nine month extension to
delinquent issuers, the NYSE stated
that, during the nine month period, it is
in frequent contact with the company
and can suspend trading and delist the
company at any point during this nine
month period should it determine that
it is not appropriate to allow the
company’s securities to continue to
trade. The NYSE further noted in
support of its proposal that, as of the
date of its letter, only six companies
were delinquent in filing their annual
report and that some of these companies
were restating their financials in
response to, or in conjunction with, an
SEC investigation.
IV. Discussion
18 15
The Commission finds that the
proposed rule change, as amended, is
consistent with the requirements of the
Act and the rules and regulations
thereunder applicable to a national
securities exchange. In particular, the
Commission finds that the proposed
rule change is consistent with Section
PO 00000
17 Id.
Frm 00134
Fmt 4703
6(b)(5) of the Act 18 which requires an
Exchange to have rules that are designed
to promote just and equitable principles
of trade, to remove impediments to and
perfect the mechanism of a free and
open market and a national market
system and, in general, to protect
investors and the public interest.19
The Commission believes that the
proposed rule change provides a
reasonable first step for dealing with
companies that fail to file annual reports
on time. The Commission notes that if
a company fails to file its annual report
within the timeframes set forth in the
proposed rule change, the Exchange
would commence suspension and
delisting procedures under Paragraph
804 of the Listed Company Manual. The
Commission also notes that at any time
during the 9 or 12 month period, as
applicable, the Exchange may suspend
trading and delist the company where it
believes it is appropriate to do so in the
public interest or for the protection of
investors. The Commission believes that
this should help to prevent an undue
amount of time from passing without
the company’s audited financial
statements being provided to the
marketplace. In addition, since the
NYSE is constantly monitoring the late
filing issuers during the 9 or 12 month
period, the NYSE has stated that it will,
and the Commission expects the NYSE
to, quickly suspend trading and
commence delisting proceedings against
any issuer during the 9 month period
should it become necessary to do so
based on the facts of the particular
situation.20 The Commission believes,
however, that the NYSE should consider
shortening the timeframes within which
a company must file annual reports
before being delisted, as well as
extending such requirements to issuers
that are late in filing their quarterly
reports with the Commission.
In addition, the Commission notes
that the Exchange appends an ‘‘.LF’’
indicator in the financial status field of
the company’s ticker symbol, distributes
that information via the low speed
ticker and through its data stream to
market vendors, and keeps an updated
list of companies that are late in their
Sfmt 4703
U.S.C. 78f(b)(5).
approving the proposed rule change, the
Commission has considered its impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
20 If a company that is late in filing its annual
report appeals any decision to suspend trading, the
NYSE has stated that the company’s securities
would not be permitted to trade on the exchange
during the appeal process. See NYSE Letter supra
note 8; see also e-mail from Annemarie Tierney,
Office of General Counsel, NYSE, to Sharon
Lawson, Senior Special Counsel, Division of Market
Regulation, Commission (April 14, 2005).
19 In
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Federal Register / Vol. 70, No. 109 / Wednesday, June 8, 2005 / Notices
filings on its website. The NYSE also
has stated that it actively encourages
vendors and subscribers to display this
indicator. The Commission believes that
these measures should provide notice to
the investing public that an issuer is late
in filing its annual report with the
Commission.21
The Commission also notes that to the
extent a late annual report filer files an
overdue report, the NYSE has indicated
it will not remove the indicator or the
company’s name from the late filer
posting on its website until all
outstanding quarterly reports have been
submitted. While this is helpful to the
public to ensure that investors are aware
of the information available on a
particular issuer, the Commission
believes the NYSE should consider
developing systems that identify all late
filers of quarterly reports, irrespective of
whether the annual report is also late.
The Commission will continue to work
with the NYSE in this area.
As noted above, Amendment No. 3
clarifies that the proposed rule change
would apply to companies that are
already late in filing their annual reports
as of the date that the Commission
approves the proposed rule change. The
Commission notes that this amendment
was published for notice and comment
and that no comments were received
addressing this issue. The Commission
believes that applying the proposal to
companies that are already late in filing
their annual reports as of the date that
the Commission approves the proposed
rule change should help to ensure that
such companies do not remain late filers
for an extended time period past the 9
or 12 month period allowed under new
Paragraph 802.01E of the Listed
Company Manual, thereby benefiting
the public interest.
In summary, the Commission believes
that the procedures being approved
herein will provide clarity to both
issuers and investors on the delisting
procedures applicable to late annual
report filers and will help to ensure that
delisting procedures are commenced no
later than 12 months after the date the
annual report was due. Further, the
Commission continues to encourage the
NYSE to further refine its policies to
address late quarterly reports and other
related matters.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,22 that the
21 The Commission urges the NYSE to continue
to encourage data vendors and subscribers to
display the indicator.
22 15 U.S.C. 78s(b)(2).
VerDate jul<14>2003
18:08 Jun 07, 2005
Jkt 205001
proposed rule change (SR–NYSE–2004–
49), as amended, is approved.
For the Commission, by the Division of
Market Regulation, pursuant to delegated
authority.23
Margaret H. McFarland,
Deputy Secretary.
[FR Doc. E5–2938 Filed 6–7–05; 8:45 am]
BILLING CODE 8010–01–P
OFFICE OF THE UNITED STATES
TRADE REPRESENTATIVE
[Docket No. WTO/DS–322]
WTO Dispute Settlement Proceeding
Regarding Measures Relating to
Zeroing and Sunset Reviews Involving
Certain Products From Japan
Office of the United States
Trade Representative.
ACTION: Notice; request for comments.
AGENCY:
SUMMARY: The Office of the United
States Trade Representative (‘‘USTR’’) is
providing notice that, at the request of
the Government of Japan, a dispute
settlement panel under the Marrakesh
Agreement Establishing the World
Trade Organization (‘‘WTO Agreement’’)
is reviewing various measures relating
to antidumping duty orders on certain
products from Japan. Japan alleges that
determinations made by U.S. authorities
concerning this product, and certain
related matters, are inconsistent with
Articles 1, 2, 3, 5, 9, 11, and 18 of the
Agreement on Implementation of Article
VI of the General Agreements on Tariffs
and Trade 1994 (‘‘AD Agreement’’),
Article VI of the General Agreement on
Tariffs and Trade 1994 (‘‘GATT 1994’’),
and Article XVI:4 of the WTO
Agreement. USTR invites written
comments from the public concerning
the issues raised in this dispute.
DATES: Although USTR will accept any
comments received during the course of
the dispute settlement proceedings,
comments should be submitted on or
before June 27, 2005, to be assured of
timely consideration by USTR.
ADDRESSES: Comments should be
submitted (i) electronically, to
FR0520@ustr.gov, with ‘‘Japan Zeroing
& Sunset’’ in the subject line, or (ii) by
fax, to Sandy McKinzy at (202) 395–
3640, with a confirmation copy sent
electronically to the address above, in
accordance with the requirements for
submission set out below.
FOR FURTHER INFORMATION CONTACT:
Elizabeth Baltzan, Associate General
Counsel, Office of the United States
Trade Representative, 600 17th Street,
PO 00000
23 17
CFR 200.30–3(a)(12).
Frm 00135
Fmt 4703
Sfmt 4703
33575
NW., Washington, DC 20508, (202) 395–
3582.
SUPPLEMENTARY INFORMATION: Section
127(b) of the Uruguay Round
Agreements Act (‘‘URAA’’) (19 U.S.C.
3537(b)(1)) requires that notice and
opportunity for comment be provided
after the United States submits or
receives a request for the establishment
of a WTO dispute settlement panel.
Consistent with this obligation, USTR is
providing notice that a dispute
settlement panel has been established
pursuant to the WTO Dispute
Settlement Understanding (‘‘DSU’’). The
panel will hold its meetings in Geneva,
Switzerland.
Major Issues Raised by Japan
With respect to the measures at issue,
Japan’s panel request refers to the
following:
• The imposition of anti-dumping
duties on Certain Cut-to-Length Carbon
Quality Steel Plate products from Japan
(64 FR 73215, 13 December 1999);
• The imposition of anti-dumping
duties on Tapered Roller Bearings, Four
Inches or Less in Outside Diameter, and
Components Thereof, from Japan (66 FR
15078, 15 March 2001);
• The imposition of anti-dumping
duties on Tapered Roller Bearings and
Parts Thereof, Finished and Unfinished,
from Japan (65 FR 11767, 6 March
2000);
• The imposition of anti-dumping
duties on Tapered Roller Bearings and
Parts Thereof, Finished and Unfinished,
from Japan (66 FR 15078, 15 March
2001);
• The imposition of anti-dumping
duties on Ball Bearings and Parts
Thereof from Japan (65 FR 49219, 11
August 2000);
• The imposition of anti-dumping
duties on Cylindrical Roller Bearings
and Parts Thereof from Japan (65 FR
49219, 11 August 2000);
• The imposition of anti-dumping
duties on Spherical Plain Bearings and
Parts Thereof from Japan (65 FR 49219,
11 August 2000);
• The imposition of anti-dumping
duties on Ball Bearings and Parts
Thereof from Japan (66 FR 36551, 12
July 2001);
• The imposition of anti-dumping
duties on Cylindrical Roller Bearings
and Parts Thereof from Japan (66 FR
36551, 12 July 2001);
• The imposition of anti-dumping
duties on Spherical Plain Bearings and
Parts Thereof from Japan (66 FR 36551,
12 July 2001);
• The imposition of anti-dumping
duties on Ball Bearings and Parts
Thereof from Japan (67 FR 55780, 30
E:\FR\FM\08JNN1.SGM
08JNN1
Agencies
[Federal Register Volume 70, Number 109 (Wednesday, June 8, 2005)]
[Notices]
[Pages 33573-33575]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E5-2938]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-51777; File No. SR-NYSE-2004-49]
Self-Regulatory Organizations; New York Stock Exchange, Inc.;
Order Approving Proposed Rule Change and Amendment No. 3 Thereto
Relating to Procedures for Companies That Fail To File Annual Reports
in a Timely Manner
June 2, 2005.
I. Introduction
On August 19, 2004, the New York Stock Exchange, Inc. (``NYSE'' or
``Exchange'') submitted to the Securities and Exchange Commission
(``Commission'' or ``SEC''), pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change codifying existing procedures
followed where companies fail to satisfy the Commission's filing
requirements for annual reports on Forms 10-K, 10-KSB, 20-F, 40-F, or
N-CSR in a timely manner. The proposed rule change was published for
public comment in the Federal Register on October 1, 2004.\3\ The
Exchange filed Amendments No. 1 \4\ and 2 \5\ on October 29, 2004 and
November 29, 2004, respectively. On December 21, 2004, the Exchange
filed Amendment No. 3 to the proposed rule change.\6\ Amendment No. 3
was published for public comment in the Federal Register on January 14,
2005.\7\ The Commission received two comment letters regarding the
proposed rule change.\8\ On March 1, 2005, the Exchange submitted a
response to the comments.\9\ This order approves the proposed rule
change, as amended.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Securities Exchange Act Release No. 50452 (September 27,
2004), 69 FR 58987.
\4\ See letter from Mary Yeager, Assistant Secretary, NYSE, to
Nancy J. Sanow, Assistant Director, Division of Market Regulation,
Commission, dated October 28, 2004 (``Amendment No. 1'').
\5\ Amendment No. 2 replaced and superseded Amendment No. 1. On
December 21, 2004, the Exchange withdrew Amendment No. 2.
\6\ Amendment No. 3 clarified that the proposed rule change
would apply to companies that are already late in filing their
annual reports as of the date that the Commission approves the
proposed rule change.
\7\ Securities Exchange Act Release No. 50982 (January 6, 2005),
70 FR 2686. Amendment No. 3 clarified that the proposed rule change
would apply to companies that are already late in filing their
annual reports as of the date that the Commission approves the
proposed rule change.
\8\ See letters from James J. Angel, Associate Professor of
Finance, McDonough School of Business, Georgetown University
(``Angel''), to Jonathan G. Katz, Secretary, Commission (``Angel
Letter''), and Edward S. Knight, Executive Vice President and
General Counsel, The Nasdaq Stock Market, Inc. (``Nasdaq''), to
Jonathan G. Katz, Secretary, Commission, dated February 4, 2005
(``Nasdaq Letter'').
\9\ See letter from Mary Yaeger, Assistant Secretary, NYSE, to
Sharon Lawson, Division of Market Regulation, Commission, dated
March 1, 2005.
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
The Exchange is proposing to codify existing procedures followed
where companies fail to satisfy the Commission's filing requirements
for annual reports on Forms 10-K, 10-KSB, 20-F, 40-F, or N-CSR in a
timely manner. The proposed rule change would apply with full effect to
companies that are already late in filing their annual report on Form
10-K, 20-F, 40-F, or N-CSR with the SEC as of the date that the
Commission approves this rule filing.\10\ Specifically, a company that
fails to file its annual report with the Commission in a timely manner
would be subject to the following procedures under new Paragraph
802.01E of the Listed Company Manual:
---------------------------------------------------------------------------
\10\ See Amendment No. 3, supra note 6.
---------------------------------------------------------------------------
Under Paragraph 802.01E, once the Exchange identifies that a
company has failed to file a timely periodic annual report with the
Commission by the later of (a) the date that the annual report was
required to be filed with the Commission by the applicable form or (b)
if a Form 12b-25 was timely filed with the Commission, the extended
filing due date for the annual report, the Exchange would notify the
company in writing of its status. The later of these two dates would be
referred to as the ``Filing Due Date.''
Within five days of receipt of this notification, the company would
be required to (a) contact the Exchange to discuss the status of the
annual report filing, and (b) if it has not already done so, issue a
press release disclosing the status of the filing. If the company
failed to issue this press release in a timely manner, the Exchange
would itself issue a press release stating that the company has failed
to timely file its annual report with the Commission.
During the nine-month period from the Filing Due Date, the Exchange
would monitor the company and the status of the filing, including
through contact with the company, until the annual report is filed.
Under the procedure, if the company failed to file the annual report
within nine months from the Filing Due Date, the Exchange would be
permitted, in its sole discretion, to allow the company's securities to
be traded for up to an additional three-month trading period depending
on the company's specific circumstances. If the Exchange determined
that an additional trading period of up to three months is not
appropriate, suspension and delisting procedures would commence in
accordance with the procedures set out in Paragraph 804.00 of the
Listed Company Manual.\11\ The new rule specifically states that a
company would not be eligible to follow the procedures outlined in
Paragraphs 802.02 and 802.03 with respect to this criteria.\12\
---------------------------------------------------------------------------
\11\ Paragraph 804 sets forth the procedures the Exchange
follows when it determines a security should be delisted, and the
issuer's right of review of such decisions.
\12\ Paragraphs 802.02 and 802.03 provide generally, among other
things, that when a listed company is not in compliance with the
Exchange's continued listing criteria, the Exchange notifies the
company of its status and the company is given the opportunity to
provide a plan advising the Exchange of the definitive action the
company intends to take that would bring it into conformity with
continued listing standards.
---------------------------------------------------------------------------
In determining whether an additional trading period of up to three-
months is appropriate, the rule specifically states that the Exchange
would consider the likelihood that the filing could be made during the
additional period, as well as the company's general financial status,
based on information provided by a variety of sources, including the
company, its audit committee, its outside auditors, the staff of the
Commission and any other regulatory body. The new procedures also state
that the Exchange strongly encourages companies to provide ongoing
disclosure on the status of the annual report filing to the market
through press releases, and that the Exchange will take the frequency
and detail of such information into account in determining whether an
additional three-month trading period is appropriate. If the Exchange
determined that an additional, up to three-month trading period was
appropriate and the company failed to file its periodic annual report
by the end of the additional period, suspension and delisting
procedures would commence in accordance with the procedures set out in
Paragraph 804.00 of the Listed Company Manual.\13\
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\13\ See also supra notes 11 and 12. In such a case, the
procedures of Paragraphs 802.02 and 802.03 would not be available,
as discussed above.
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[[Page 33574]]
The Commission notes that new Paragraph 802.01E permits the
Exchange to suspend trading immediately and commence delisting
procedures for a late annual report filer in accordance with Paragraph
804. Specifically, the new rule states that if, at any time, the
Exchange deemed it necessary or appropriate in the public interest or
for the protection of investors, trading in any security could be
suspended immediately, and, in accordance with the procedures set out
in Paragraph 804.00, application made to the Commission to delist the
security.
III. Comments
The Commission received a total of two comment letters: the Nasdaq
Letter and the Angel Letter,\14\ and a response from the NYSE.\15\
Angel stated that the proposal seemed reasonable overall, but that the
NYSE should place an indicator on the ticker symbol of companies that
are late in making required filings with the SEC. The Angel Letter also
noted that Nasdaq puts an ``E'' on the end of a ticker symbol of
companies late in required Commission filings and that the same
identifier should be seen on NYSE late filers. Angel also recommended
expanding the scope of the proposal to companies that are late in
filing their quarterly reports, noting that this is just as important,
if not more so, than late filers of annual reports.
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\14\ See supra note 8.
\15\ See supra note 9.
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Nasdaq stated that the proposal does not ``go nearly far enough to
protect investors.'' Nasdaq also stated that it does ``not believe that
a market should offer what is essentially a blanket nine months filing
extension to delinquent issuers'' and that ``the NYSE should be
required to adopt a more reasonable timeframe to respond to annual
report filing delinquencies.'' In support of this, Nasdaq notes that
the issuer's financial statements would be at least a year old at the
end of NYSE's nine month period. In addition, Nasdaq stated that
quarterly reports are an important element of information which is
available to investors and that without current financials, it is
impossible for a marketplace to determine whether a listed issuer
complies with continued listing standards. Further, Nasdaq noted that
its own procedures cover late annual and interim reports and if an
issuer fails to timely file required reports it is promptly notified it
will be delisted unless it appeals.\16\
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\16\ Nasdaq further stated that appeal hearings with respect to
filing delinquencies are scheduled on an expedited basis and
generally occur within three weeks.
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In response to these comments, the NYSE stated that it agrees that
investors should be provided with timely notice of companies that fail
to file annual reports on time.\17\ The NYSE further stated that
``since July 2004, the Exchange has monitored and disseminated
transparent information on companies that fail to satisfy the
Commission's requirement to file their annual financials in a timely
manner.'' The NYSE further stated that it ``appends an `.LF' indicator
in the financial status field of the company's ticker symbol and
distributes that information via the low speed ticker and through [its]
data stream to market vendors.'' The Exchange also stated that it keeps
an updated list of companies that are late in their filings on its
website, and notes the late filing status on the company's data page on
its Web site. In response to Angel's and Nasdaq's recommendation of
identifying and expanding the scope of the proposal to companies that
are late in filing their quarterly reports, the NYSE stated that it is
currently involved in conversations with the Commission regarding the
identification of companies that have failed to timely file quarterly
reports. The NYSE also noted that to the extent a company files an
overdue annual report, the NYSE will not remove the .LF indicator or
the company's late filing status on its website until such time as all
outstanding interim reports are up to date. In response to Nasdaq's
comment that the proposal would give a blanket nine month extension to
delinquent issuers, the NYSE stated that, during the nine month period,
it is in frequent contact with the company and can suspend trading and
delist the company at any point during this nine month period should it
determine that it is not appropriate to allow the company's securities
to continue to trade. The NYSE further noted in support of its proposal
that, as of the date of its letter, only six companies were delinquent
in filing their annual report and that some of these companies were
restating their financials in response to, or in conjunction with, an
SEC investigation.
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\17\ Id.
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IV. Discussion
The Commission finds that the proposed rule change, as amended, is
consistent with the requirements of the Act and the rules and
regulations thereunder applicable to a national securities exchange. In
particular, the Commission finds that the proposed rule change is
consistent with Section 6(b)(5) of the Act \18\ which requires an
Exchange to have rules that are designed to promote just and equitable
principles of trade, to remove impediments to and perfect the mechanism
of a free and open market and a national market system and, in general,
to protect investors and the public interest.\19\
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\18\ 15 U.S.C. 78f(b)(5).
\19\ In approving the proposed rule change, the Commission has
considered its impact on efficiency, competition, and capital
formation. 15 U.S.C. 78c(f).
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The Commission believes that the proposed rule change provides a
reasonable first step for dealing with companies that fail to file
annual reports on time. The Commission notes that if a company fails to
file its annual report within the timeframes set forth in the proposed
rule change, the Exchange would commence suspension and delisting
procedures under Paragraph 804 of the Listed Company Manual. The
Commission also notes that at any time during the 9 or 12 month period,
as applicable, the Exchange may suspend trading and delist the company
where it believes it is appropriate to do so in the public interest or
for the protection of investors. The Commission believes that this
should help to prevent an undue amount of time from passing without the
company's audited financial statements being provided to the
marketplace. In addition, since the NYSE is constantly monitoring the
late filing issuers during the 9 or 12 month period, the NYSE has
stated that it will, and the Commission expects the NYSE to, quickly
suspend trading and commence delisting proceedings against any issuer
during the 9 month period should it become necessary to do so based on
the facts of the particular situation.\20\ The Commission believes,
however, that the NYSE should consider shortening the timeframes within
which a company must file annual reports before being delisted, as well
as extending such requirements to issuers that are late in filing their
quarterly reports with the Commission.
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\20\ If a company that is late in filing its annual report
appeals any decision to suspend trading, the NYSE has stated that
the company's securities would not be permitted to trade on the
exchange during the appeal process. See NYSE Letter supra note 8;
see also e-mail from Annemarie Tierney, Office of General Counsel,
NYSE, to Sharon Lawson, Senior Special Counsel, Division of Market
Regulation, Commission (April 14, 2005).
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In addition, the Commission notes that the Exchange appends an
``.LF'' indicator in the financial status field of the company's ticker
symbol, distributes that information via the low speed ticker and
through its data stream to market vendors, and keeps an updated list of
companies that are late in their
[[Page 33575]]
filings on its website. The NYSE also has stated that it actively
encourages vendors and subscribers to display this indicator. The
Commission believes that these measures should provide notice to the
investing public that an issuer is late in filing its annual report
with the Commission.\21\
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\21\ The Commission urges the NYSE to continue to encourage data
vendors and subscribers to display the indicator.
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The Commission also notes that to the extent a late annual report
filer files an overdue report, the NYSE has indicated it will not
remove the indicator or the company's name from the late filer posting
on its website until all outstanding quarterly reports have been
submitted. While this is helpful to the public to ensure that investors
are aware of the information available on a particular issuer, the
Commission believes the NYSE should consider developing systems that
identify all late filers of quarterly reports, irrespective of whether
the annual report is also late. The Commission will continue to work
with the NYSE in this area.
As noted above, Amendment No. 3 clarifies that the proposed rule
change would apply to companies that are already late in filing their
annual reports as of the date that the Commission approves the proposed
rule change. The Commission notes that this amendment was published for
notice and comment and that no comments were received addressing this
issue. The Commission believes that applying the proposal to companies
that are already late in filing their annual reports as of the date
that the Commission approves the proposed rule change should help to
ensure that such companies do not remain late filers for an extended
time period past the 9 or 12 month period allowed under new Paragraph
802.01E of the Listed Company Manual, thereby benefiting the public
interest.
In summary, the Commission believes that the procedures being
approved herein will provide clarity to both issuers and investors on
the delisting procedures applicable to late annual report filers and
will help to ensure that delisting procedures are commenced no later
than 12 months after the date the annual report was due. Further, the
Commission continues to encourage the NYSE to further refine its
policies to address late quarterly reports and other related matters.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\22\ that the proposed rule change (SR-NYSE-2004-49), as amended,
is approved.
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\22\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Market Regulation,
pursuant to delegated authority.\23\
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\23\ 17 CFR 200.30-3(a)(12).
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Margaret H. McFarland,
Deputy Secretary.
[FR Doc. E5-2938 Filed 6-7-05; 8:45 am]
BILLING CODE 8010-01-P