Wachtell Lipton Discusses SEC Expansion of Five Business Day Debt Tender Offer Criteria

On June 30, 2026, the SEC’s Division of Corporation Finance published an exemptive order (the “Debt Order”) permitting tender offers for non-convertible debt securities with a minimum offering period of five business days (a “Five Business Day Tender Offer”) if …

Davis Polk Discusses Potential SEC and CFTC Updates to Classification Rules for Innovative Financial Products

The SEC and CFTC (the “Commissions”) have jointly requested public comment on how to draw clearer regulatory boundaries for classifying, within statutory bounds, innovative derivatives and related products that implicate the jurisdiction of the Commissions and whether there are opportunities …