SEC Flash Report - September 2016

September 2016

SEC Requests Comments on Management, Certain Security Holders, and Corporate Governance Disclosure Requirements 

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Last week, the Securities and Exchange Commission published a request for comment on the disclosure requirements of Subpart 400 of Regulation S-K, which relate to management, certain security holders and corporate governance matters.  The request is part of the Disclosure Effectiveness Initiative, a broad-based staff review of the SEC’s disclosure rules designed to improve the disclosure regime for both companies and investors.  The request follows the SEC’s proposal to eliminate redundant and outdated disclosure requirements in July 2016,[1] the Concept Release on Regulation S-K published in April 2016,[2] and the Request for Comment on the effectiveness of certain financial disclosure requirements of Regulation S-X published in September 2015.[3] The request will also inform the Commission’s study on Regulation S-K, which is required by the Fixing America’s Surface Transportation (FAST) Act. 

The request for comment can be found here on the SEC’s website.  Comments should be provided within 60 days following publication of the request for comment in the Federal Register.

For questions related to matters discussed above, please contact Jeff Lenz or Paula Hamric

[1] Further information regarding the proposal can be found here in our Flash Report.
[2] Further information regarding the Concept Release can be found here in our Flash Report.  Our comment letter can be found here
[3] Further information regarding the Request for Comment can be found here in our Flash Report. Our comment letter can be found here.