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SEC Filer Status Proposal : Key Themes Emerging From The Public Comment Process - Executive Remuneration

In May 2026, the SEC proposed amendments that would replace the current three filer categories with two, large accelerated filers (LAFs) and non-accelerated filers (NAFs), and eliminate smaller reporting company (SRC) status. The public float threshold for LAF status would rise from $700 million to $2 billion, the minimum reporting period would increase from 12 months to 60 months, and transitions would require meeting the threshold for two consecutive years. NAFs would be exempt from the Section 404(b) auditor attestation requirement and the advisory vote on executive compensation. The SEC estimates that about 81% of reporting companies would qualify as NAFs, though they represent roughly 6.5% of total public float. Commenters disagreed on balancing reduced costs against investor protections, focusing on the $2 billion threshold, the 404(b) exemption, the seasoning period and the broader scaled disclosure.

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