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According to this recent Society - EY - FEI Disclosure Committee survey, 96% of public company respondents have a formal disclosure committee (see FN 60) or comparable group with similar responsibilities.

The survey revealed these key disclosure committee practices among Society respondent companies:

Committee Composition

• Disclosure committee members are most commonly appointed by the CFO, CEO, and/or the GC or other in-house securities counsel.
• Standing committee members nearly always include the CAO or Controller, Chief IR officer, CLO/GC or equivalent, and the Corporate Secretary, and typically (>80%) include these positions or their equivalents: Director of Financial Reporting, CCO, CRO, Treasurer, in-house securities counsel, CFO, Financial Planning & Analysis, and Tax.
• Observers/periodic attendees most commonly include outside legal counsel and the external auditor, as well as (though less common) the Audit Committee chair, Chief Sustainability Officer (or equivalent).

Scope

• In terms of documents/filings, disclosure committees nearly always review SEC periodic reports (e.g., Form 10-Ks, Form 10-Qs) and commonly (67%) review earnings releases (text and slides/supplemental materials).
• In terms of types of disclosures, disclosure committees nearly always review accounting and financial reporting disclosures (97%), typically review non-GAAP financial metrics (72%), and commonly review litigation disclosure (58%), as shown here:

Organization/Administration

• The CEO most commonly chairs the activities of the committee; the Head of Financial/SEC Reporting and/or Corporate Secretary/Assistant or Deputy Corporate Secretary most commonly coordinates them. The Controller and/or CAO most commonly both chairs and coordinates committee activities in those cases where both activities reside with the same role.
• Committees most commonly meet quarterly for both earnings and periodic reporting.
• Disclosure committee processes normally include a formal committee charter (which is most commonly approved by the committee itself); nearly half include written disclosure controls & procedures (DC&P). The Disclosure Committee charter, DC&P or other organizational documents usually address the committee's purpose, responsibilities, composition & structure, and meetings (e.g., protocol, schedule, recordkeeping).
• Most companies maintain formal meeting minutes that document meeting particulars including member attendance and other participation, coverage of agenda topics, etc., and report to the Audit Committee orally about the meetings at regular Audit Committee meetings.