If a company has 500 or more shareholders and more than $10 million in assets, it is required by the Securities Exchange Act of 1934 to register with the SEC and to file periodic reports, even if the company’s stock is not publicly traded.
To comply with these reporting requirements, the company would typically need to file a Form 10 with the SEC, which provides detailed information about the company’s business, operations, and financial condition. Once the company has registered with the SEC, it would be required to file periodic reports on Form 10-Q (quarterly) and Form 10-K (annually), as well as current reports on Form 8-K when certain significant events occur.
Keep in mind, however, that even if the company’s stock does not trade on a public market, its shareholders may still be able to sell their shares in a private transaction. As a result, it is important for the company to ensure that it is complying with all applicable securities laws and regulations to avoid any potential liabilities.