Insight
On March 20, the SEC adopted a number of disclosure reforms under the 2015 Fixing America’s Surface Transportation Act, or “FAST” Act. Despite the questionable connection between disclosure and surface transportation, the reforms reflect the SEC’s commitment to making disclosures simpler and more meaningful. Among other things, the reforms will enable companies to:
- exclude the first of three years in Management’s Discussion and Analysis if that year has been discussed in a prior filing;
- omit certain confidential information in some exhibits without having to file a confidential treatment request;
- limit property disclosures to material properties; and
- limit attachments to material agreements filed as exhibits, so long as the attachment does not contain material information and is not otherwise disclosed.
Further details on the reforms will be available shortly in The Securities Edge, our securities and governance blog. If you have any questions in the meantime, please contact Gunster securities law and corporate governance practice leader Bob Lamm.
