On September 17, the SEC voted unanimously to propose new disclosure rules regarding short-term borrowing practices and to publish interpretive guidance on the SEC’s current MD&A disclosure requirements relating to liquidity and capital resources. The proposed rules would expand the universe of companies required to provide disclosure of short-term borrowings beyond bank holding companies and will be reconsidered following a 60-day public comment period. The interpretive MD&A guidance will become effective immediately upon publication in the Federal Register.