SEC Issues Interpretive Guidance Regarding Liquidity and Capital Resources Disclosures

As a companion release to the proposed amendments to Management's Discussion and Analysis of Financial Condition and Results of Operations ("MD&A") released by the Securities and Exchange Commission ("SEC") on September 17, 2010, and in light of increasingly complex financing arrangements undertaken by registrants, the SEC has issued interpretive guidance summarizing and emphasizing existing SEC rules and guidance regarding liquidity and capital resources disclosures in MD&A. The SEC's new interpretive guidance became effective as of September 28, 2010. Commission Guidance on Presentation of Liquidity and Capital Resources Disclosures in Management's Discussion and Analysis Release Nos. 33–9144; 34–62934 (September 17, 2010).