April 16, 2012

Corp Fin Disclosure Guidance: Financial Institution Sample Letter on Structured Note Offerings

On Friday, Corp Fin posted this sample letter – courtesy of the Office of Capital Markets Trends – that has been sent to certain financial institutions in connection with their structured note offerings. The letter provides comments applicable to prospectus supplements and ’34 Act reports after the Staff’s review of takedowns of structured notes from shelf registration statements.

This WSJ article notes that at least two companies have already sent confidential registration statement submissions to Corp Fin…

Corp Fin Updates Financial Reporting Manual (Again)

On Friday, Corp Fin updated its Financial Reporting Manual for issues related to scaled disclosure for smaller reporting companies, filing requirements for reverse acquisitions, the treatment of related businesses in significance testing, revisions pursuant to ASU 2011-12, as well as other changes.

Chamber Blankets DC Subway Station Closest to SEC HQ with Ads

In what has to be a certain waste of money, according to this Bloomberg article, the Chamber of Commerce hopes to influence the SEC in a money-market fund rulemaking by the use of a “so-called station domination ad buy consisting of more than 30 posters, banners and ‘backlit dioramas’ on the train platforms, above fare card machines and even on the floor.” Maybe the money would have been better off spent renting a giant Foghorn Leghorn suit for someone to hand out flyers in…

Interesting piece in Financial Times on Friday entitled “Our faith is fraying in the god of money.” I always find taxi drivers to be enlightening and a good indicator about what the masses are thinking (ask them about CEO pay!)…

– Broc Romanek