TheCorporateCounsel.net

A recent SEC Institute blog points out that there are three changes from the SEC’s 2020 overhaul of the MD&A disclosure requirements that have become frequent topics for Staff comments:

– Critical accounting estimate disclosures
– Quantitative and qualitative disclosures about material changes
– Meaningfully addressing liquidity and capital resources

The blog suggests that one reason for this may be simple fact that a lot of companies simply aren’t updating their disclosures to comply with the new requirements, noting that “old and obsolete beliefs that disclosure changes will attract negative attention from the SEC create resistance that is difficult to overcome,” even when it comes to complying with new disclosure requirements. The blog also offers up some links to its prior commentary on these topics to help companies understand what the Staff is looking for when it comes to MD&A disclosures.

– John Jenkins