The SEC recently published a request for comment on Regulation S-X (see:, which signals an important step in the Commission’s continuing review of disclosure requirements. The request for comment is focused on financial statement disclosures for entities other than a registrant, such as, for example, financial statements for an acquired business, financial statements for a non-wholly owned entity, and financial statements for a guarantor. In the context of acquisitions, the request for comment asks about the Rule 3-05 financial statements and the utility of pro forma information, as well as the significance tests for determining whether financial statements of a target or acquired entity are required to be provided.