Many readers will recognize the table above as being required by Item 303(a)(5) of Regulation S-K. The Securities and Exchange Commission added this disclosure requirement in 2003, explaining in the adopting release:
Aggregated information about a registrant’s contractual obligations in a single location will provide useful context for investors to assess a registrant’s short- and long-term liquidity and capital resource needs and demands.
How clear is the required tabular disclosure? Does the “1-3 years” column require disclosure of obligations due in year 1? If so, it duplicates the obligations disclosed in “Less than 1 year”. Does the “3-5 years” column include year 3 obligations? If so, that column duplicates year 3 obligations included in the “1-3 years” column. If the SEC intended overlapping disclosures, why? If it did not, are these column headings clear? Can it really be said that this table provides “useful context for investors”?
