When we recently wrote about ways that companies can improve their disclosures to the Securities and Exchange Commission, a common suggestion for both clarity and brevity was to use charts, graphs, and other illustrations. A concern, however, is whether the information contained in those graphics must be searchable by the SEC’s electronic filing system or include accompanying text that is.
A new Compliance and Disclosure Interpretation by the SEC’s Division of Corporation Finance addresses that very issue regarding “graphic, image, audio, and video material” and the question, “May a Commission filing contain graphics (such as .gif or .jpeg image files) that include information that is not text-searchable?”
