SEC Report On Regulation S-K Disclosure

Just in time for the holidays!  On December 20, 2013, the staff of the Securities and Exchange Commission (the "SEC") released its Report on Review of Disclosure Requirements in Regulation S-K, as mandated by Section 108 of the Jumpstart Our Business Startups Act (the "JOBS Act").  Section 108 required the SEC to issue its report within 180 days of its enactment on April 5, 2012, but all of the other rulemaking requirements imposed on the SEC made that timetable difficult to meet. 

The Report reviews the history of all the disclosure items set forth in Regulation S-K, but does not propose any specific groundbreaking changes.  Instead, the Report identifies several areas for further study and information gathering, including (1) emphasizing a principles-based approach over "static requirements," (2) evaluating whether "scaled disclosure," i.e., less disclosure for smaller companies, would be appropriate (anyone remember Regulation S-B?), (3) considering the