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Deloitte comments on SEC's concept release on business and financial disclosure required by Regulation S-K

Published on: Jul 15, 2016

Deloitte & Touche LLP comments on the SEC's concept release, "Business and Financial Disclosure Required by Regulation S-K," issued on April 13, 2016.

An excerpt from the comment letter is shown below:

We support the Commission’s consideration of ways it might update the current disclosure regime to facilitate timely, material disclosure by companies as well as investor access to that information. We believe that the most effective disclosures are clear, concise, and focused on matters that are both material to investors and specific to the company. We also believe that the current SEC disclosure regime largely supports effective disclosure and have encouraged our clients to heed the SEC’s call to improve disclosures under the existing rules. Many companies have done so, and we believe that some of these voluntary improvements serve as examples of the strengths and limitations of the current disclosure regime that the Commission should consider as it modernizes the regime.

The body of this letter contains some general thoughts and observations on the potential future of public company disclosures that we believe the Commission should keep in mind as it moves forward with its disclosure effectiveness initiative. We have also attached an appendix that provides input on some of the more specific questions raised in the concept release on ways the SEC could improve its current disclosure requirements. In formulating our response to this concept release, we have drawn on our direct experiences with a large number of companies that file with the SEC. We also have drawn on our more general observation of public company disclosure trends, both inside and outside the SEC reporting regime.

Full text of the comment letter is available below.


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