October 25, 2010

The SEC’s “Final” Five-Year Strategic Plan

Last week, the SEC released its final 50-page strategic plan for the next five years – 2010 through 2015 – as required by the Government Performance and Results Act of 1993. A draft of the plan was issued last October, at which time I blogged about how I dislike five-year horizons for any plan since unforeseen events often change priorities and needs (and here is my blog about the SEC’s prior strategic plan).

A quick perusal of the strat plan doesn’t reveal anything earth-shattering. On pages 6-8, the limits of the SEC’s resources – and limited budget – are explored. The Corp Fin-related content mostly is on pages 21-24 and pages 32-35. It appears there will be a survey conducted by the SEC regarding the quality of disclosures and the SEC’s disclosure requirements (a topic that I recently tackled on “The Mentor Blog“). The influence of the new Investor Advisory Committee is felt on pages 36-38.

A New SEC Comment Letter Service: Comment-by-Comment

In this podcast, Ganesh Rajappan of LogixData provides some insight into how LogixData’s SEC comment letter service works (here is a demo), including:

– How does LogixData’s comment letter database differ from the existing databases out there?
– How many SEC comment letters are in your database?
– Can you give an example of how a customer might use the ability to search for comments issued by a specific Corp Fin examiner?

PCAOB “Bars from Association”: A Vague and Ambiguous Standard

It’s great to see more securities lawyers entering into the blogosphere. Michael MacPhail of Holme Roberts has been blogging in his “Securities Defense Blog” about PCAOB investigations, including this one about a potentially vague standard to be barred from practicing before the PCAOB.

– Broc Romanek