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Say goodbye to 'Tandy' language in comment letters

Joe Mont | October 6, 2016

Effective immediately, Tandy representations are no longer needed in filing reviews, according to new guidance from the Securities and Exchange Commission’s Division of Corporation Finance.

Beginning in the mid-1970s, SEC staff began to include in filing review comment letters what became known as “Tandy” representations, a name derived from the Tandy Corporation, the former parent company of RadioShack and the first company to receive a letter with this language. Tandy letters required a company to acknowledge in writing that the disclosure in the document was its responsibility and to affirmatively state that it would not raise the SEC review process and acceleration of effectiveness as a defense in any legal proceeding.

In 2004, CorpFin and the Division of Investment Management announced a new policy to...

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