How to improve, modernize and—perhaps—simplify the Securities and Exchange Commission’s disclosure regime has long been the Holy Grail of securities law. Corporate filings, many bemoan, have become bloated and nearly impenetrable for the average investor, forcing them to wade through voluminous documents filled with lawyer-pleasing redundancies and an everything-but-the-kitchen-sink approach to financial information and risk factors.
Attempts at reform have come and gone over the years with only occasional and limited success. Now, however, one of the most ambitious efforts is yet gaining traction. On April 13, the SEC voted to publish a Concept Release seeking public comment on nearly 350 questions about modernizing disclosures required under Regulation S-K. Over thirty years ago, the Commission expanded and reorganized Reg S-K to be the central repository for non-financial statement disclosure requirements.
