October 10, 2011

Corp Fin Updates Financial Reporting Manual (Again)

Last week, Corp Fin updated its Financial Reporting Manual for issues related to reporting requirements in an acquisition or disposition made by a variable interest entity, subsidiary guarantee release provisions, transitional registration statement options for first-time IFRS adopters, as well as other changes. The good news is that Corp Fin continues to add a summary of changes that comprise the current update at the beginning of the Manual. Last revised in July (and April, December and October before that), Corp Fin has been updating the Manual much more frequently than in the past, deciding to do so a little bit at a time rather than major rewrites.

In addition, the SEC has posted the Charter for the new Advisory Committee on Small and Emerging Companies.

More on "STA's Beneficial Ownership Processing Study"

Last week, I blogged about a study from the Securities Transfer Association that evaluates 20 Broadridge invoices and claims that transfer agents can process beneficial ownership services cheaper than Broadridge. In this Securities Technology Monitor article, Broadridge responds as reflected in this excerpt:

"The latest survey by the STA consists of twenty imaginary prices for services it doesn't offer, has no idea how to perform, and would never have to deliver," says Chuck Callan, senior vice president of regulatory affairs for Broadridge in a statement to Securities Technology Monitor on Friday morning. "The STA continues to dodge requests to disclose its rate cards. Its data does not reconcile to any published rates."

Callan went on to say that although the STA has been interested in providing proxy distribution services for Street-name shareholders that are better, faster, cheaper and more accurate than competitors "its interest is free from any commitment to write the check."

He suggests that the "market-rates" for proxy mailings to Street name shareholders could come out to be far higher than the regulated rates. The reason: a study conducted by Compass Lexecon, an economics consulting firm on behalf of Broadridge which examined over 12,000 invoices for "actual work performed," showed that the market-based rates issuers pay Broadridge for delivering proxies to registered shareholders are "substantially higher" than regulated rates for sending proxies to Street-name shareholders.

Webcast Transcript: "Current Developments in Capital Raising"

We have posted the transcript for our recent webcast: "Current Developments in Capital Raising."

- Broc Romanek