On June 9, 2016, the SEC's interim final rule adding new
Item 16 to Part IV of Form 10-K, which is available here, took effect.1 The rule
expressly authorizes, but does not require, an issuer to include in
its Form 10-K a summary of the information required by the form if
each summary item is hyperlinked to the related, more detailed
disclosure item elsewhere in the report. If the summary discusses
information that is incorporated by reference into the Form 10-K
from an exhibit that is filed with the form, the summary must
include a hyperlink to the discussion in the accompanying
exhibit.
Prior to the adoption of the rule, issuers were not prohibited
from voluntarily providing a Form 10-K summary. Therefore, the rule
will likely have little impact, except on those issuers who
currently provide a Form 10-K summary that does not use hyperlinks
for some or all of the disclosure topics included in the summary.
If such issuers elect to continue to provide a Form 10-K
