On July 26, 2016, the SEC's Division of Corporation Finance (Division) revised and replaced Question 140.02 of its Regulation S-K compliance and disclosure interpretations (C&DIs). The revised C&DI states that, if a selling shareholder is not a natural person, in addition to disclosing any material relationships between the registrant and the selling shareholder entity, the registrant must disclose under Item 507 of Regulation S-K information about any entities or natural persons who have:

The registrant must identify each person or entity and describe the nature of any relationships.

Question 140.02 had previously stated that, if a selling shareholder is an entity and not a natural person, a company must identify in its registration statement the person or persons who have voting or investment control over the company's securities that the entity owns.

On July 26, the Division also withdrew Question 240.04 of its Regulation S-K C&DIs. Question 240.04, issued in July 2008, had stated that an issuer with a resale registration statement naming several investment funds as selling shareholders must name the natural persons who have or share voting or investment power for each fund as part of its Item 507 disclosure, even if voting or investment power for any fund is controlled by an investment committee consisting of a large number of individuals who each have a vote to approve the exercise of such power and, therefore, no single person exclusively possesses the power to vote, acquire, or dispose of securities held by the fund.

For a questionnaire that can be used in registered secondary offerings of securities to help collect and verify information relating to stockholders selling securities as part of the offering, see Standard Document, Selling Stockholder Questionnaire.