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SEC Redoubles Focus on Climate Change, ESG Disclosures

The Securities and Exchange Commission (SEC) announced in recent weeks multiple efforts to highlight climate change in corporate disclosures and to increase scrutiny and, potentially, enforcement focus on company disclosure...more

Keeping Current With Form 8-K: A Practical Guide

Form 8-K requires public companies to make prompt disclosures about a large number of specified events. Although Form 8-K does not mandate current reporting of all material events, it goes a long way toward requiring public...more

SEC Refreshes Its Business, Legal Proceedings and Risk Factor Disclosure Requirements

The business world has changed a lot in the last three decades, and, as a result of recent amendments to Item 101 of Regulation S-K, the description of a company’s business included in registration statements and periodic...more

COVID-19: Updating Risk Factor Disclosure in SEC Filings

As the COVID-19 pandemic evolves, companies are experiencing a host of adverse consequences and gaining insight into additional potential risks of the pandemic to their businesses. At the same time, general uncertainty...more

COVID-19: SEC Provides Additional Relief and Guidance for Public Companies

In further recognition of the challenges to conducting business during the COVID-19 pandemic: ..On March 25, 2020, the Securities and Exchange Commission extended through July 1, 2020, and clarified the conditions for, the...more

SEC Provides Guidance on Disclosure of Key Performance Indicators and Metrics

On January 30, 2020, the SEC issued Commission Guidance on Management’s Discussion and Analysis of Financial Condition and Results of Operations. The guidance provides a framework for ensuring that disclosure of key...more

Confidential Treatment Process Gets Easier

The SEC has approved rule changes that significantly simplify the process for public companies to redact confidential information from the exhibits required to be filed as part of SEC reports and registration statements....more

Recent Enforcement Action Serves as a Reminder of the Need to Complete Audit Firm Review of Interim Financial Statements Before...

On Friday, the Securities and Exchange Commission announced that it had settled enforcement actions against five companies for violating the Regulation S-X requirement that interim financial statements included in quarterly...more

SEC Adopts Disclosure Update and Simplification Rules

Last week, the Securities and Exchange Commission voted to amend disclosure requirements “that have become redundant, duplicative, overlapping, outdated, or superseded, in light of other Commission disclosure requirements,...more

SEC Expands Scope of Smaller Reporting Company Definition and Requires Inline XBRL for Tagged Data

On June 29, 2018, the Securities and Exchange Commission adopted amendments expanding the definition of a smaller reporting company (“SRC”) and requiring the use of Inline eXtensible Business Reporting Language (“XBRL”) for...more

SEC Chief Accountant Addresses 2018 Baruch College Financial Reporting Conference

In a speech delivered at last week’s 2018 Baruch College Financial Reporting Conference, SEC Chief Accountant Wes Bricker discussed objectives of financial reporting and its importance to the markets. Mr. Bricker revisited...more

Board Oversight of Cybersecurity

Cybersecurity is one of the highest priority issues for public company executives and directors. This note shares our views—developed over our involvement in the aftermath of many cybersecurity events as well as counseling on...more

CAQ Releases New Non-GAAP Measures Tool for Audit Committees

While the frequency of SEC comments on companies’ disclosure of non-GAAP measures has subsided, it remains important for audit committees to ensure their companies’ disclosures comply with applicable non-GAAP disclosure...more

Corp Fin Director Discusses Policy, Outreach and Future Areas of Focus

Earlier this month, SEC Division of Corporation Finance Director William Hinman delivered the keynote address at the Practising Law Institute’s Seventeenth Annual Institute on Securities Regulation in Europe. Director Hinman...more

SEC Proposes Dodd-Frank Pay-Versus-Performance Disclosure Rules

Overview - On April 29, 2015, the Securities and Exchange Commission (SEC) voted 3-2 to propose new rules requiring companies to disclose the relationship between executive compensation “actually paid” and the...more

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