Over on Cooley’s “CapitalXchange,” this blog highlights the 28-page comment letter that Cooley recently submitted to the SEC on its proposal seeking to rethink Regulation S-K. As you can tell when you read the comment letter, a lot of thought was poured into it by our team and it’s nicely organized with an easy-to-understand format. Here are the primary themes:
- Materiality reset
- Capital raising: Streamline rules where the juice isn’t worth the squeeze
- Registration statements and periodic reports: Simplify and modernize
- Proxy statements: Cut the fluff
- Earnings releases: Let companies communicate clearly
Here are the 110 comment letters that the Staff has received on SEC Chairman’s Atkins request for comment from back in January – and here’s the 1100 comments letters that the Staff received on last year’s solicitation of comment on Item 402.
Authored by
Broc Romanek