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Corporate Governance SEC Comment Letter Process Form 10-K

WilmerHale

SEC Staff Comment Letters Continue to Seek Enhanced Climate-Related Disclosures

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While the Securities and Exchange Commission’s (SEC) new climate-related disclosure rules remain pending, recent comment letters show that the SEC staff is not waiting for the rules to be finalized in order to seek more...more

Paul Hastings LLP

Public Company Update: Things to Keep in Mind for the 2024 10-K Season

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As we head into year-end, annual reporting season is just around the corner. Over the past 12 months, the SEC has been active on the rulemaking front, resulting in numerous new disclosure obligations for issuers during the...more

Dorsey & Whitney LLP

Governance and Disclosure Considerations from the SEC’s Climate Change Comment Letters

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The SEC’s Division of Corporation Finance has issued a sample comment letter, and sent actual comment letters to a series of public companies, asking for additional Form 10-K disclosure on topics addressed in the SEC’s 2010...more

BCLP

Have You Updated Your Approach to MD&A?

BCLP on

The next Form 10-K filing for most companies will be their first filing required to comply with the revised Management’s Discussion and Analysis (Item 303 of Regulation S-K) requirements adopted by the SEC in November 2020....more

White & Case LLP

SEC Issues Sample Comment Letter as it Ramps Up Scrutiny of Climate Disclosures

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On September 22, 2021, in a step that emphasizes the SEC's increased focus on climate change disclosure, the SEC's Division of Corporation Finance ("Corp Fin") issued a sample letter for public companies containing comments...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

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The staff of the Division of Corporation Finance (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) published a sample comment letter on climate change disclosures on September 22, 2021. A brief statement that...more

Opportune LLP

2018 SEC Comment Letter Trends & Disclosure Best Practices

Opportune LLP on

As we wind down the third quarter of 2018 and turn our attention toward year-end disclosures, it is helpful to review U.S Securities and Exchange Commission (SEC) comment letter trends to improve financial statement...more

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