SEC Zeroes in on MD&A Disclosures

Yesterday the Securities and Exchange Commission took two significant actions relating to the MD&A disclosures in annual and quarterly reports of public companies.

First, it proposed amendments to MD&A requirements that would, if adopted, make significant and long-overdue improvements to a central disclosure requirement of the U.S. securities laws. Second, it issued guidance on the presentation of performance metrics in MD&A, which will take effect immediately upon publication in the Federal Register. In connection with the MD&A proposal, SEC Chair Clayton and Commissioners Lee and Peirce each issued statements on climate-related disclosures in SEC filings.

For our memo on the proposed MD&A amendments, click here. 

For our memo on the performance metrics guidance, click here.

For our memo on climate-related disclosures in SEC filings, click here.