Tandy Reps: No Longer Required for Acceleration Requests Too!

As John blogged recently, Corp Fin recently announced that it would no longer require companies to include “Tandy letter” representations in their responses to Staff comments. The question that I got from some members was: “I presume Tandy reps are still required for acceleration requests?” The answer is “no, the Staff no longer seeks Tandy language in acceleration requests.” This is consistent with the rationale for no longer requiring the language in comment response letters…

Here’s a blog by Keith Bishop highlighting that he had questioned whether Tandy reps were enforceable several months ago. By the way, these were called “Tandy” representations because of a position that the SEC Staff took in the mid-’70s against the Tandy Corporation…