May 21, 2018

Drafting Integrated Reports: How Hard Is It?

Some advocates have been pushing companies to put together “integrated reports.” To illustrate how easy they think it is to do so, a couple of researchers recently prepared this 40-page mock “Integrated Report” for ExxonMobil (starts at page 18). As they describe in this Forbes article, they used publicly-available info – the 10-K, proxy statement, citizenship report, annual report, etc. – and said it took them about 40 hours to edit & organize it into the framework.

Some might say that the 40-hour estimate to draft an integrated report isn’t realistic. Perhaps their effort overlooks the amount of time associated with ensuring the various components of an integrated report work together appropriately – and all the layers of review that a company (who has real potential liability for the end product) must go through.

By the way, according to this announcement, the next step for these researchers is to create an “Integrated Report Generator Tool” – which will “provide stakeholders with a way to create integrated reports.”

Poll: Challenges of Drafting Integrated Reports

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Bank Examiners Can’t Override Privilege: 7-Firm Memo

This “7-Firm Memo” asserts that bank examiners aren’t entitled to privileged material from financial institutions – and shouldn’t condition favorable examination results & relationships upon “voluntary” waivers. The analysis relies heavily on recognition of the attorney-client privilege by the SEC & DOJ. Both agencies have said they don’t require privilege waivers in order to deem a company “cooperative.”

Liz Dunshee