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ARTICLE · 05 APRIL 2019

SEC Adopts Disclosure Simplifications

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Item 5 of Form 20-F has been modified to be consistent with the amendments to Item 303.

United StatesCorporate/Commercial Law

The SEC has adopted amendments (Amendments) to certain of its regulations, rules and forms to modernize and simplify certain disclosure requirements as mandated by the 2015 Fixing America's Surface Transportation Act (FAST Act). The most significant changes are described below.

S-K Item 303 - MD+A

Previously, the instructions to Item 303(a) specified that MD+A should generally cover the three-year period covered by the financial statements, and that reference to the five-year selected financial data may be necessary where trend information is relevant. The Amendments permit registrants to omit discussion of the earliest of the three years if, in management's view, that discussion is not necessary to understand the company's financial condition, changes in financial condition, and results of operations, and (as would generally be the case for all but new registrants), that year was discussed in a prior EDGAR filing, and the location in such prior filing is

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