Disclosure Reform A Must

In a recent speech, Commissioner Gallagher provided another perspective on the need for the SEC to focus on disclosure reform.  Gallagher acknowledges the importance of tackling disclosure reform, even amidst the challenges faced by the SEC to focus on Dodd-Frank Act rulemaking mandates.  Given the press of other business, Gallagher outlined a few specific areas where the SEC might make targeted changes.  For example, he highlighted "layering" disclosures.  This is consistent with the way in which investors seem to prefer to receive information, as was indicated in financial literacy study that was mandated by the Dodd-Frank Act.  Gallagher also suggests streamlining 8-K disclosures.  He notes that, "The gateway question, in looking at streamlining or curtailing the proliferation of 8-K filings, should be whether investors really need all of this welter of immediately updated information in order to know what is material about a company's current condition. So, while