Comment Letter to Concept Release on Foreign Private Issuer Eligibility
The Manhattan Institute for Policy Research is a 501(c)(3) nonprofit think tank committed to developing and disseminating new ideas that foster greater economic choice and individual responsibility. Director of Legal Policy James R. Copland and Legal Policy Fellow C. Jarrett Dieterle of the Manhattan Institute submit these comments in response to the Securities and Exchange Commission’s Concept Release on Foreign Private Issuer Eligibility that was published in the Federal Register on June 9, 2025.
We write to raise several points of consideration for the Commission as it deliberates on potential next steps to take with regard to Foreign Private Issuers (FPIs). While we appreciate the Commission’s concern with the current FPI landscape, we hope to use this letter to explore nuanced regulatory and private actor tools that could address this issue while not throwing the proverbial baby out with the bathwater.
James R. Copland is a senior fellow at the Manhattan Institute and director of Legal Policy. C. Jarrett Dieterle is a legal policy fellow for the Manhattan Institute.
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