While public companies have dedicated significant time and resources to update their Securities and Exchange Commission (SEC) filings to adequately and accurately report the effects and risk of COVID-19 on their business, the SEC has continued to press forward with its regular rulemaking agenda. To help companies stay informed and compliant with the SEC’s changes beyond pandemic guidance, Bass, Berry & Sims attorney Andrea Orr authored an article published by Accounting Today that covers updates from the past several months.

In the article, Andrea addresses the most SEC significant disclosure changes, including:

  • Continued modernization of Regulation S-K with August 2020 amendments to the description of business, legal proceedings and risk disclosure requirements.
  • Human capital resources disclosure requirements under Item 101 (Description of Business).
  • Risk factor disclosures under Item 105 that exceed 15 pages now require such disclosure to be preceded by summary of factors that cause investment into the company to be speculative or risky.
  • February Interpretive Guidance related to the disclosure of key performance indicators (KPIs) and metrics in  management’s discussion and analysis of financial condition and results of operations (MD&A).
  • Revised disclosure requirements for financial statements relating to acquisitions and dispositions of businesses to enhance information for investors while eliminating unnecessary costs and burdens.
  • Adopted amendments to Rule 3-10 of Regulation S-X to reduce the subsidiary guarantor financial statement requirements in periodic reports for companies that have registered debt guaranteed by subsidiaries.

The full article, “Key Disclosure Changes in 2020,” was published by Accounting Today on November 3 and is available online.