December 4, 2015

More on “Corp Fin Comments: More Readable Responses Produces Better Results?”

A few months ago, I blogged about a study that I personally don’t think holds much water. I do think that Corp Fin examiners prefer responses to comments that are more readable – but at the end of the day, I don’t think they impact the length of time it takes for an examiner to review the responses, nor impact the likelihood of another round of comments, etc. Anyways, here are responses that I received from members:

– I like the referenced study even though it uses the term “bong rating agencies” when it means “bond rating agencies.” Maybe Colorado has such an agency now?

– I have been preaching about using plain English since I was converted in 1998. I have a fine track record in clearing comments and filings quickly, and in getting “no reviews.” I am convinced that it is partly due to using plain English as much as I can.

– Aside from the many good things that have happened to me in my life, the best thing to happen to me was Arthur Levitt’s plain English effort.

– I recommend that everyone who writes SEC disclosures – and everyone who writes contracts – to subscribe immediately to a service called “WordRake.” If you don’t have WordRake, you don’t have !#$%. Google WordRake. It’s a plug-in of some sort. But the real value is the WordRake newsletter, which comes by email every week. It contains writing tips that are clear, well written, entertaining, and customized particularly for lawyers.

Meanwhile, in response to my blog about Edgar having trouble with graphics, a member noted that sometimes she has found that financial statements were “missing” when viewed using Internet Explorer, but they were visible when using Chrome or Firefox browsers…

Gunjumping: Did Tinder’s CEO Do It?

It’s not uncommon for a CEO to conduct an interview during the ramp up to an IPO that crosses the line into “gun-jumping.” The most famous case in modern history is the interview in Playboy by Google’s two co-founders. Now Tinder’s CEO may have crossed the line ahead of that company’s IPO, as noted in this Gizmodo article (which I hate to cite since it misspells the SEC’s name: “Security & Exchange Commission”). Here’s the Evening Standard interview that allegedly violates the quiet period…

Cybersecurity: Impacting Creditworthiness

It shouldn’t be a surprise that cybersecurity issues is growing as a factor when analyzing a company’s creditworthiness, as this Moody’s report highlights…also see this excellent blog by Doug Greene about lagging board oversight of cybersecurity…

Broc Romanek