Further to our prior report: "Libor Risk Disclosure Trending Up," Intelligize reported that disclosure of Libor's phase-out as a Form 10-K risk factor has increased more than 600% over the last year - at least in some cases influenced by or at the directive of the SEC. Recent examples (in addition to those identified in last week's Society Alert and prior reports) include Valero Energy Corporation, American Airlines, and Pfizer. Another company - Great Elm Capital Corp. - was advised via SEC comment letter to supplement its registration statement Risk Factors disclosure to include the potential elimination of Libor.
See also Fox Rothschild's "LIBOR Sunset: What It Means and Why It Matters"; these prior reports: "LIBOR Phase-Out Risk Considerations," "Reminder: SEC Focused on Cyber, Brexit, LIBOR-Related Disclosure," and "SEC Looking for Better Brexit/Cyber/Libor-Related Risk Disclosure"; and additional information & resources on our Financial Reporting page.