My partner @amico_jeffrey has some good comments here, so thought I would add some additional perspectives.
To me, the most interesting topic here is the non-integration safe harbors. Lawyers sometimes worry that a perfectly legal stock offering can be tainted by another one that is declared non-compliant. And, in that case, the SEC could "integrate" the two and declare them both bad.
Why does this matter? Because, as a company, if you sell stock in a non-compliant way, the buyer has the right to simply put the shares back to you and get her money back. Not a good outcome, particularly if you've already spent the money!
With that in mind, one of the key concerns about direct listing (vs IPOs) is whether a company could raise money privately and then turn around and do a direct listing (since direct listing are not capital raising events).
"Integration" is the key risk - could the direct listing get tainted by the SEC integrating it with the private financing and potentially declaring them both bad? We of course don't know this for sure, but read the Safe Harbor #3 in the SEC relief, as it seems to address this.
One interpretation of the safe harbor is that as long as you have a 30-day gap between closing the private financing and doing the direct listing, you are safe from integration risk.
All caveats that this is early, not yet a rule, simply my interpretation, etc. - but, if this holds, this could significantly alter the relative attractiveness of direct listings relative to traditional IPOs.
