The movement for disclosure effectiveness and simplification appears to be gaining real momentum, both in terms of official rule-setting activities and voluntary efforts by a growing number of companies. Of special interest is that over the past six months, the SEC has issued a flurry of documents as part of its major Disclosure Effectiveness Initiative. Two of these documents could portend significant changes in the SEC reporting requirements.
First, in April, the SEC issued a lengthy concept release, Business and Financial Disclosure Required by Regulation S-K, soliciting comments on 340 questions on a broad range of both overarching and specific disclosure matters relating to Regulation S-K, which is the central source of non-financial statement disclosures for SEC registrants. The SEC received over 26,000 comment letters on the concept release, the vast majority of which are form letters advocating expanded disclosures regarding political spending, overseas tax payments, amounts of taxes owed to the United States by foreign subsidiaries, and sustainability plans.
