Your MD&A is Getting a Last Minute Facelift

CECL survey 2019

The SEC, on Thursday, voted to approve amendments to Regulation S-K which are intended to improve readability and usability of the Management’s Discussion & Analysis (MD&A) section of SEC filings, as well as eliminate redundancy, and omit information not considered material to stakeholders, while adding a handful of new discussion or disclosure items. The guidance is part of a broader effort to overhaul the disclosure requirements for issuers. Some of the more significant changes you can expect to see in future filings are expected to:

  • Streamline and simplify the requirements of the overall MD&A, and certain other sections
  • Clarify and improve existing disclosures surrounding liquidity and capital resources
  • Eliminate or revise tables for Selected Financial Data and Supplementary Financial Information
  • Require a discussion of SEC guidance relating to critical accounting estimates

The SEC did not elaborate on how they determined what information was not considered material to stakeholders. Additionally, the SEC voted to adopt these amendments not only to modernize Regulation S-K but to do it in a manner that reduces the costs and burdens on registrants while continuing to provide relevant material information to investors. Registrants are required to comply with the new rules beginning with the first fiscal year ending on or after the date that is 210 days after publication in the Federal Register. For a link to the complete announcement:  https://www.sec.gov/news/press-release/2020-290. For more information contact Angelo N. Spaneas, Assurance Senior Manager at: aspaneas@bnncpa.com or anyone on your BNN team.

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.