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ARTICLE · 21 SEPTEMBER 2010

SEC Votes to Propose New Rules and Publish Interpretive Guidance Regarding Short-Term Borrowings Disclosure

O'Melveny & Myers LLP
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On September 17, 2010, the Securities and Exchange Commission unanimously voted to propose rules that would require issuers to provide additional disclosures regarding short-term borrowings in filings with the Commission.

United StatesFinance and Banking

Article by Marty Dunn , David Lavan , Bjorn Hall and Leanna Albrecht

On September 17, 2010, the Securities and Exchange Commission unanimously voted to propose rules that would require issuers to provide additional disclosures regarding short-term borrowings in filings with the Commission.  The Proposing Release is available here.

The Commission also unanimously voted to publish an interpretive release to provide guidance regarding the liquidity and capital resources disclosure required in the "Management's Discussion and Analysis of Financial Condition and Results of Operations" section ("MD&A") of a company's quarterly and annual reports filed with the Commission.  The Interpretive Release is available here. 

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