In this new CLS Blue Sky Blog, Sullivan & Cromwell reiterates the importance of thoroughly considering the potentially extensive implications on the company's business associated with the LIBOR phase-out, Brexit, cybersecurity, and other potentially material risks or developments, and reevaluating/updating related financial reporting disclosures. In addition to suggesting relevant disclosure and practical considerations in each of these risk areas, the memo highlights other areas of likely SEC focus based on recent speeches by SEC Chair Clayton and Staff, and SEC rulemaking and accounting standard setting-related disclosure updates.
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See also Arnold & Porter's "Preparing for the End of LIBOR"; these recent reports: "Brexit Risk Disclosure Examples, "LIBOR Phase-Out Risk Considerations," "Form 10-K Risk & Other Disclosure Considerations," "Brexit-Related Risk Framework," "Reminder: SEC Focused on Cyber, Brexit, LIBOR-Related Disclosure," "SEC Looking for Better Brexit/Cyber/Libor-Related Risk Disclosure," "Risk Factor Disclosure Considerations, Board Risk Oversight & Much More!"; and additional resources here, here, here and here. This post first appeared in the weekly Society Alert!
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