December 4, 2023
An annual update of observations on new developments and highlights of considerations for calendar-year filers preparing Annual Reports on Form 10-K.
Each year we offer our observations on new developments and highlight select considerations for calendar-year filers as they prepare their Annual Reports on Form 10-K. This alert touches upon recent rulemaking from the U.S. Securities and Exchange Commission (“SEC”), comment letters issued by the staff of the SEC’s Division of Corporation Finance (the “Staff”), and trends among reporting companies that have emerged throughout the last year.
An index of the topics described in this alert is provided below.
I. New Disclosure Requirements for 2023
A. Update on Repurchase Rule
B. Cybersecurity Risk Management, Strategy, and Governance Disclosures
1. Risk Management and Strategy
2. Governance
C. Rule 10b5-1 Plan Disclosures for Section 16 Officers and Directors
D. Compensation Clawback Disclosures
II. Disclosure Trends and Considerations
A. Climate Change
B. Human Capital
C. Generative Artificial Intelligence
D. Geopolitical Conflict
E. Potential Government Shutdown
F. Inflation and Interest Rate Concerns
III. SEC Comment Letter Trends
IV. Other Reminders and Considerations
A. Disclosure Controls and Procedures
B. Characterization of Legal Proceedings
C. EDGAR Next
D. Filing Requirement for “Glossy” Annual Report
E. Cover Page XBRL Disclosures
I. New Disclosure Requirements for 2023
Throughout 2023,...
About this page Our systems have detected unusual traffic from your computer network. This page checks to see if it's really you sending the requests, and not a robot. Why did this happen? IP addr...