Comments on SEC’s proposed rule


In our response to the SEC’s Proposed Rule, Management’s Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information, the firm expressed its support for the Commission’s efforts to modernize, simplify, and enhance the effectiveness of public company disclosure requirements by reducing duplicate disclosures and focusing on material information. The firm further commends the Commission for considering comments previously submitted in response to the April 13, 2016 Concept Release, Business and Financial Disclosure Required by Regulation S-K, when drafting the current proposal.

While we do not object to eliminating Regulation S-K Items 301 and 302, as proposed, the firm encourages the Commission to continue to reach out to investors to gauge the overall utility of selected financial data and supplementary financial information before finalizing rulemaking in this area, since members of the investment community generally expressed support for retaining S-K Item 301 and/or Item 302 in their responses to the 2016 Concept Release.

Download our letter here to read more about the firm’s views.




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