Regulation S-K (including MD&A)
The SEC’s amendments to Regulation S-K intended to modernize, simplify, and enhance Management’s Discussion and Analysis (MD&A), streamline supplementary financial information, and eliminate the requirement to provide certain selected financial data were posted to the Federal Register on January 11, establishing an effective date of February 10. The changes will impact many SEC filings, including Forms 10-K, 10-Q, 20-F, and 40-F and many registration statements.
As with any change in administration, however, there is the possibility that the Biden administration could postpone the effective date of these amendments. The rules are required to be applied beginning with the first fiscal year ending on or after August 9, 2021. Barring federal action, the amended rules can be early adopted at any time after the effective date (on an item-by-item basis), as long as the disclosures are responsive to an amended item in its entirety.
Read our In depth, SEC amends MD&A and eliminates selected financial data, for details about the amendments.
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