As reported in last week's Society Alert and this Rants to Riches post, last week, the SEC proposed amendments to eliminate redundant, duplicative, overlapping, outdated, or superseded disclosure requirements. For those who haven't yet read the 318-page SEC release, this new post from Gibson Dunn summarizes the Staff's approach to - and provides examples for - each of these types of disclosure categories. For example, in the redundant or duplicative requirements category, the proposed rules would delete the Reg. S-X related parties disclosure requirement in view of requirements elsewhere.
As previously reported, the proposed rules also solicit comment on certain disclosure requirements that overlap with GAAP to determine next steps. Among the notable requirements identified by Gibson Dunn that are proposed to be modified, eliminated or referred to FASB under this aspect of the proposal is Reg. S-K's Item 103 requirement to disclose legal proceedings.
See also this Shearman & Sterling memo.
Stay tuned for more information.