On January 30, 2020, the US Securities and Exchange Commission (SEC) provided guidance (MD&A Guidance) regarding the disclosure of key performance indicators and metrics used in the Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) section of SEC filings. This commission-level guidance, which reflects the SEC’s interpretation of existing MD&A requirements, becomes effective on the date of its publication in the Federal Register, which will make it applicable to annual reports on Form 10-K and Form 20-F that are currently being prepared. In addition, on January 24, 2020, the SEC’s Division of Corporation Finance issued three MD&A compliance and disclosure interpretations (C&DIs).
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