A company that is not required under Section 13(a) or 15(d) of the Exchange Act to file periodic reports with the SEC but nevertheless files these reports.

A company becomes subject to the duty to file Exchange Act reports under Section 15(d) when it conducts an SEC registered offering, such as an A/B exchange offer. If the company's duty to file periodic reports under Section 15(d) is later suspended in accordance with Section 15(d), and the company continues to file periodic reports despite the suspension of its reporting duties, the company becomes a voluntary filer.

A voluntary filer is considered a non-reporting company for some purposes even though it is filing Exchange Act reports with the SEC (see non-reporting issuer).

For more information on voluntary filers, see Voluntary Filers: SEC Reporting Requirements Chart. For more information on the circumstances under which companies are required to file periodic reports under the Exchange Act, see Practice Note, Exchange Act Registration: Overview.