Form 10-K Risk & Other Disclosure Considerations

By Randi Morrison posted 01-03-2019 08:50 PM

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In this recent memo: "SEC Highlights Disclosure Topics for Upcoming Filings," Davis Polk provides helpful guidance on how companies can be responsive to SEC Chair Clayton's and Staff's recent calls (see our prior reports here, here, here and here: "SEC Looking For…) for better Brexit, LIBOR phase-out, and cybersecurity risk disclosure in their Form 10-Ks. The memo includes a series of questions for companies to consider that may bear on the scope and content of their disclosure in each of these key risk areas.

Relatedly, Sullivan & Cromwell's "Key Considerations for Fiscal Year 2018 Form 10-K and 20-F Filings" suggests companies review and consider updating or expanding their LIBOR phase-out, Brexit and cybersecurity disclosures in light of informal guidance imparted in recent SEC Chair and Staff remarks. The memo also identifies particular areas of SEC Staff scrutiny relative to the new revenue recognition, leases, and credit loss accounting standards based on Chief Accountant Wesley Bricker's recent remarks, and new Form 10-K/20-F form updates that issuers should consider for fiscal 2018 filings.

Access additional resources here, here, here and here. This post first appeared in the weekly Society Alert!

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