United States

SEC seeks comment on certain financial disclosure requirements


As part of its Disclosure Effectiveness Initiative, the SEC recently issued a Request for Comment on the Effectiveness of Financial Disclosures about Entities Other Than the Registrant. The request for comment relates to the following Regulation S-X rules, along with certain related requirements:

  • Rule 3-05, Financial Statements of Businesses Acquired or to be Acquired
  • Rule 3-09, Separate Financial Statements of Subsidiaries Not Consolidated and 50 Percent or Less Owned Persons
  • Rule 3-10, Financial Statements of Guarantors and Issuers of Guaranteed Securities Registered or Being Registered
  • Rule 3-16, Financial Statements of Affiliates Whose Securities Collateralize an Issue Registered or Being Registered

The SEC seeks to understand (a) how well these requirements are informing investors, (b) challenges registrants face in preparing the required disclosures and (c) potential changes to the requirements that could enhance the information provided and promote efficiency, competition and capital formation.