The Securities and Exchange Commission has proposed to modernize Regulation S-K Items 101, 103, and 105.  The comment period for this proposal closes today.  The Corporations Committee of the Business Law Section of the California Lawyers Association recently submitted this comment letter which responds to many of the SEC's specific requests for comment.  This is the Committee's second comment letter since the founding the CLA.  In March, the Committee submitted this response to the SEC's request for comments on earnings releases and quarterly reports. 

The CLA is a nonprofit, voluntary organization and the new home of the Sections of the State Bar of California and the California Young Lawyers Association.  Steve Hazen and I currently serve as co-chairs of the Committee.