Trade Commission Seeks Ownership Disclosure in Disputes
Published Date: 4/30/2026
Proposed Rule
Summary
The U.S. International Trade Commission wants to update its rules so companies involved in Section 337 investigations must share who owns or financially supports them. This change helps keep things clear and fair during trade dispute cases. If you want to share your thoughts, make sure to send comments by June 29, 2026!
Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
Mandatory Ownership Disclosure for Parties
If you are a nongovernment party or seek to intervene in a Section 337 investigation, you must file a disclosure statement identifying any parent corporation and any entity (not natural persons) that owns your stock. For each entity listed you must give its identity, business address, and, if a legal entity, place of formation.
Must Disclose Litigation Funders and Approval Rights
Parties must disclose any person or entity (other than counsel) that provides funding specifically for the Section 337 investigation (excluding personal loans, bank loans, or insurance) and any person or entity whose approval is necessary for litigation or settlement decisions, including the nature of those terms and conditions.
Disclosure Timing: File With Your Filing
The disclosure statement must be filed concurrently with key filings: with the complaint, with the respondent's response, with motions to intervene, with enforcement complaints and responses, with petitions to modify or rescind orders, and with requests for advisory opinions. Related parties who act together may file a single disclosure statement.
Listed Exemptions Narrow Disclosure Scope
The rule excludes natural persons as owners from the ownership disclosure, excludes counsel from the list of entities whose funding must be disclosed, excludes bank loans and insurance from the funding disclosure, and does not require disclosure of funding that is part of a contingency fee agreement with counsel.
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Key Dates
Department and Agencies
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