On November 19 the SEC issued significant amendments to the disclosure requirements governing Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A). The amendments to Item 303 of Regulation S-K and related guidance continue the SEC’s decades-long effort to elicit improved MD&A disclosure. The changes build on major interpretive guidance issued by the SEC in 1989 and 2003 and feature major themes of the SEC’s current disclosure effectiveness initiative.
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