On June 1, the SEC issued a new Interim Final Rule, amending Item 16 of
Part IV to the Form 10-K, specifically permitting issuers to
include a summary section in an Annual Report on Form 10-K.
The summary section will permit issuers to summarize information
contained in other parts of the Form 10-K that is filed, provided
the items are presented fairly and accurately. While the use of
summary sections in Annual Reports was not prohibited by the SEC,
the new interim final rule will require that any summary now
contain hyperlinks to the more fulsome, relevant sections of the
Form 10-K.
The SEC did not provide any guidance as to the length, content
or location of a summary section. However, the SEC did express
concern that investors may choose only to focus on the summary
section instead of the full Annual Report. Based on the SEC's
approach to registration statements containing summary sections, we
would anticipate that any summary in a Form 10-K will be required
to
