Resources & Thought Leadership Library | SD Mayer

Going Private: Strategic Considerations for Delisting

Written by Admin | September 12, 2025

Public companies sometimes decide to delist and "go private" for compelling strategic and financial reasons. Take Walgreens, for example—after nearly a century on the New York Stock Exchange, the retail chain recently completed a $10 billion private equity deal. Following years of regulatory challenges and operational hurdles, management determined that delisting offered the best path forward for their "ambitious turnaround plans."

This strategy gives companies the freedom to work with experienced private equity partners while eliminating the constant pressure of Wall Street scrutiny. However, going private isn't a simple exit strategy—it can be nearly as complex as the initial public offering process.

Navigating SEC Requirements

The Securities and Exchange Commission takes a close look at going-private transactions to protect unaffiliated shareholders. Companies pursuing this path, along with their controlling shareholders and affiliates, must navigate detailed SEC requirements, particularly Rule 13e-3.

Here's what you need to know: The SEC permits public companies to deregister their equity securities when they have fewer than 300 shareholders of record (or fewer than 500 if the company lacks significant assets). Once your shareholder count drops below these thresholds, you may no longer need to file periodic SEC reports.

Essential Disclosures Under Rule 13e-3

To comply with SEC Rule 13e-3 and Schedule 13E-3, your going-private transaction must include comprehensive disclosures covering:

  • Transaction purposes: Document your reasons for going private, including any alternatives you considered and why you rejected them
  • Fairness assessment: Demonstrate both substantive fairness (appropriate pricing) and procedural fairness throughout the process
  • Professional opinions: Include any reports, opinions, and appraisals that materially relate to the transaction

These rules exist to protect shareholders, and many states have additional takeover statutes providing dissenting shareholders with appraisal rights. Remember, delisting significantly reduces liquidity for investors by creating a limited trading market for your stock.

The Stakes Are High

Transparency and fairness aren't just good business practices—they're legal requirements. SEC scrutiny can result in costly damages and penalties if your company treats minority shareholders unfairly or makes misleading disclosures.

Weighing Your Options

To successfully navigate SEC scrutiny and avoid litigation, structure your going-private transaction with complete transparency, procedural fairness, and appropriate pricing. Management must also carefully evaluate the long-term implications.

Consider these potential challenges:

  • High transaction costs
  • Legal and regulatory risks
  • Limited access to capital markets
  • Reduced brand visibility
  • Decreased liquidity for remaining shareholders
  • Potential debt burden from leveraged buyouts

Making the Right Decision for Your Business

Going private represents a significant strategic shift that requires careful planning and expert guidance. The process demands thorough understanding of SEC requirements, strategic assessment of your company's unique situation, and meticulous attention to shareholder protection.

Ready to explore your options? Our team specializes in helping companies navigate complex financial transitions. We'll work with you to evaluate whether going private aligns with your strategic goals and assist with SEC financial reporting requirements. Let's structure a deal that's right for your specific situation.

Contact SD Mayer & Associates today to discuss your company's path forward.