December 11, 2013

Confidential Treatment Request Confusion: Rule 24b-2/406 vs. Rule 83

I’ve heard that there is some confusion as to when you need to send a CTR to the SEC’s FOIA office. You don’t need to do so for a Rule 24b-2 or 406 confidential treatment request – those CTRs should be only sent to the SEC’s Office of the Secretary (& don’t direct it to the attention of any individual or other office at the Commission). Only this address and the return address should appear on the envelope conveying a Rule 24b-2 or 406 confidential treatment request:

Office of the Secretary
Room 10915
Mail Stop 1090
Securities & Exchange Commission
100 F. Street NE
Washington, DC 20549-1090

In comparison, a FOIA letter must be sent for confidential treatment requests under Rule 83. As noted on page 40 of my “Confidential Treatment Requests Handbook,” Rule 83 requires three different submissions (ie. letter to Corp Fin Staffer reviewing your filing; comment letter response filed via Edgar and the letter to the SEC’s FOIA office)…

How is Morale at the SEC? A 2013 Job Satisfaction Survey

Two years ago, I blogged about the results of a biannual government-wide “Federal Human Capital Survey” as it pertained to the SEC. Now, a new government-wide survey is out – and here is the SEC’s 2013 Federal Employee Viewpoint Survey. Overall, the SEC did not fare well compared to the other 36 federal agencies included in the survey – coming in 35th on Job Satisfaction; 33rd on Talent Management; 33rd on Results-Oriented Performance Culture and 26th on Leadership & Knowledge Management.

Transcript: “Audit Committees in Action – The Latest Developments”

We have posted the transcript from our recent webcast: “Audit Committees in Action: The Latest Developments.”

– Broc Romanek