Other CFOs of foreign companies mentioned that trading volume could be an effective benchmark. They recommended that the decades-old guideline of having 300 U.S. shareholders be updated to 1,000 or 3,000, and institutional investors should be excluded from the final count. A letter signed by finance chiefs from companies based in the United Kingdom, Sweden, German, Norway and other nations, said 300 shareholders typically represents less than 1 percent of the total number of a company's investors.
On the other hand, John Stanhope, CFO of Australia's Telstra of Melbourne, supports the current threshold of 300 shareholders, but said a test of the dollar amount of the issuer's assets is irrelevant and would further make exiting the SEC's hold difficult. Telstra has since said it plans to deregister, according to its comment letter.


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