Article

Transitional FAQs: Amended Regulation S-K Items 101, 103 and 105

Nov 09, 2020
Nov 09, 2020
0 min. read
#
Audit Financial reporting SEC matters

In response to questions about the revised disclosure requirements and related rules in Release No. 33-10825, Modernization of Regulation S-K Items 101, 103, and 105, the SEC recently issued transitional FAQs, which address matters such as:

  • Whether a prospectus supplement filed on or after November 9, 2020 (the effective date of Release No. 33-10825), must comply with the new rules if the related Form S-3 became effective before November 9, 2020
  • The fact that the new Item 101 rules did not change Item 1 of Form 10-K, which only requires disclosures regarding the development of the registrant’s business for the fiscal year covered by the Form 10-K
  • Whether a registrant must always provide a full discussion of the general development of its business pursuant to new Item 101(a) (or new Item 101(h) for a smaller reporting company) in an annual report or registration statement that requires Item 101 disclosure

Subscribe to Financial Services Insights

Sign up now for a monthly update on the marketplace trends important to financial institutions, capital markets, asset management and other financial services. Select your preferences today.

Contact our financial services professionals

Complete this form and an RSM representative will be in touch shortly.