Securities Offering Reform: Prospectus Delivery Proposal

On November 3, 2004, the Securities and Exchange Commission proposed new rules (http://www.sec.gov/rules/proposed/33-8501.pdf) that would significantly modify and advance the registration, communications and offering framework of the Securities Act of 1933. The proposals would enhance the disclosure requirements under that Act and the Securities Exchange Act of 1934 — which have both undergone significant changes since the enactment of the Sarbanes-Oxley Act of 2002 — and continue the SEC’s long-term effort to integrate the disclosure requirements, as well as other offering processes, under both of these Acts. The release is subject to a 75-day comment period, which expires on January 31, 2005, and the SEC is seeking comment on virtually all of the topics covered in its proposals.