At an open meeting today, the SEC voted to take an interim step in its disclosure effectiveness project, proposing amendments “to eliminate redundant, overlapping, outdated, or superseded provisions,” in light of subsequent changes to SEC disclosure requirements as well as GAAP and IFRS requirements. This is not the big overhaul of Reg S-K expected as a result of that project, but rather, according to Chair White, a “targeted update” that addresses discrete areas that can be modified in advance of the broader effort. The proposal also represents the SEC’s efforts in part to implement the FAST Act, which, among other things, required the SEC to eliminate provisions of Reg S-K that are duplicative, overlapping, outdated or unnecessary. (See this PubCo post.) The proposal will be open for comment for 60 days.
According to the press release, the proposal covers:
- Whether to delete requirements that duplicate U.S. GAAP, IFRS or other SEC disclosure requirements;
- Whether to delete requirements that overlap with GAAP, IFRS or other SEC disclosure requirements to the extent they are no longer be useful to investors, or instead to integrate the incremental information or modify or refer them to the FASB for potential incorporation into GAAP;
- Whether to amend outdated requirements that have become obsolete as a result of the passage of time or changes in the regulatory, business or technological environment, including whether to propose to require additional disclosure of information as appropriate; and
- Whether to amend superseded requirements that are inconsistent with recent legislation, more recently updated SEC disclosure requirements or more recently updated GAAP to reflect these more recent updates.
As of the time of this post, the proposing release has not been posted.