In a Bloomberg BNA article, I provided insight on what future additional updates the SEC Staff could be focusing on following the Commission’s announcement of proposed amendments to Regulation S-K last week. The article quotes Elizabeth Murphy, an associate director in the SEC Division of Corporation Finance, from an October 18 Association of Corporate Counsel conference discussion saying the SEC has “more to come from our Reg S-K disclosure initiative,” but did not specify any particular recommendations to Regulation S-K the Commission plans to focus on. I noted that the Staff might continue to focus on MD&A disclosures and Regulation S-K’s Item 101, the narrative description of the business. In those areas, many comments on the concept release urged the SEC to “move from prescriptive rules to a more principles-based approach,” I explained in the article. “Given how fundamental these S-K sections are to SEC filings generally, it seems reasonable to believe the SEC Staff would develop recommendations to these rules for Commission consideration.”
The full article, “More SEC Proposals on Disclosure Rule Coming, Official Says,” was published on October 18, 2017, by Bloomberg BNA and is available online.