• May use 20-day rule to make filing effective
• Roadshow could begin in a couple of weeks

Navan is pressing ahead with its initial public offering despite the ongoing federal government shutdown and may tap a rarely used provision that sidesteps typical regulatory approvals for stock listings, according to three sources briefed on the matter.

Legal advisors plan to update the S-1 filing for the Palo Alto, California-based corporate travel and expense management company as soon as today, which would start the clock for a 20-day period in which the registration becomes effective unless the US Securities and Exchange Commission (SEC) acts, the sources explained. The update may include a new share count, pricing, and other details.

MapLight Therapeutics became the first company to file for a listing under the provision on Monday. The strategy is in response to the SEC furloughing workers and halting IPO reviews amid a budget impasse in Congress.

The workaround was also used by a couple of issuers during the 2018-2019 government shutdown. Cash-hungry companies are seen as prime candidates to use the legal loophole, other advisors have said.

But in Navan’s case, the company wants to take advantage of a hot IPO market, one of the sources noted. “They know the market’s strong — it’s not them; it’s the market that’s hungry.”

With public market investors showing interest in new technology issuance in particular, the source said Navan and its advisors “don’t want to let a good market go to waste.”

Navan, formerly known as TripActions, has been preparing for a public debut for years, but its listing plans have been beset by delays related to poor market conditions, a company executive told this news service last year.

Goldman Sachs and Citigroup are Navan’s lead book-running managers. Jefferies, Mizuho, and Morgan Stanley are joint bookrunners. BNP Paribas, Citizens, Oppenheimer, and MUFG are among the other bookrunners.

Cooley and Fenwick and West are Navan’s legal advisors.

In its S-1 filed in September, Navan reported 12-month revenue of USD 613m across 10,000-plus customers, and gross bookings of USD 7.6bn. The company is still losing money. It reported a net loss of USD 100m for the six months that ended on 31 July.

Andreessen Horowitz, Coatue, Goldman Sachs, and Lightspeed are among its backers.

The company could raise as much as USD 800m in the IPO, one of the sources said. A roadshow to market the offering to investors could begin in a couple of weeks, he said, though he cautioned that plans could change, especially if the government shutdown ends.

A Navan spokesperson declined to comment.