June 30, 2025

Would Streamlined Disclosures Help Investors? The SEC’s Investor Advocate Is on the Case

Last week, the SEC’s Office of the Investor Advocate – which is also known as the “OIAD” – announced that it had delivered this 24-page report to Congress on its objectives for the fiscal year ending September 30, 2026. Priorities include:

1. Investor research and testing on existing and proposed disclosures to retail investors.

2. Informing SEC activities and policy priorities through data collected from nationally representative surveys.

3. Addressing and advocating for the priorities and concerns of retail investors affected by financial fraud, including through the Interagency Securities Council.

4. Private market investments in retirement accounts.

5. China-based variable interest entities listed on U.S. exchanges.

The report describes the Investor Advocate’s disclosure-related objectives as:

Among other things, the Investor Advocate will explore different approaches to making required disclosures more user-friendly and comprehensible to investors, particularly retail investors, while also considering the extent to which this may add to the costs and burdens on issuers and other providers of disclosure. For example, investors may benefit from highlighting or simplifying certain information, streamlining disclosure requirements, and/or reducing or eliminating repetitive disclosures.

A central aspect of this effort will be ongoing engagements by the Investor Advocate with retail investors and other relevant parties to develop a more thorough understanding of how investors use this information and to solicit a range of views on how to improve the effectiveness of the current disclosure system.

I heard a lot of complaints last week at the SEC’s Executive Compensation Roundtable – from both companies and investors – that executive compensation disclosure in particular has become very unwieldly. Hopefully, that means that when the OIAD solicits a range of views, it can find a few folks who can see the benefits of streamlined – and less burdensome – disclosures.

If you’re curious about why this report was delivered, it’s one of two that Exchange Act Section 4(g)(6) requires the Investor Advocate to deliver each year. This one is “forward-looking” for the forthcoming fiscal year. The other – due December 31st – reports on activities for the preceding fiscal year.

The Investor Advocate delivers the Report directly to Congress without any prior review or comment from the Commission, any Commissioner, any other officer or employee of the Commission outside of the OIAD or the Office of Management and Budget. So it doesn’t necessarily reflect the priorities of the Commission.

Liz Dunshee

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