Developments of Note
SEC Issues Guidance on MD&A Disclosure
The SEC issued an interpretive statement containing views of the SEC staff about "disclosure that should be considered by public companies while preparing annual reports for the year recently ended." As the quoted text makes clear, the SEC intends that public companies should apply this interpretive guidance to annual reports filed this spring for the year ended December 31, 2001. The SEC has not made clear whether or to what extent it believes the guidance applies to annual or quarterly reports that are filed between today and April 1, 2002 (the due date for Form 10-K Annual Reports for the calendar year ended 12/31/01).
The interpretive statement addresses disclosure in three areas:
