- increasing flexibility in the discussion of historical periods in the management discussion and analysis (MD&A),
- allowing companies to redact confidential information from most exhibits without filing a confidential treatment request, and
- incorporating technology to improve access to information on the cover page of certain filings.
Most of the amendments are already in effect except for the requirements to tag data on the cover pages of certain filings, which are subject to a three-year phase-in.
Scott Holley, a member in the Nashville, Tenn., office of Bass, Berry & Sims PLC, explains, “The change that is likely to have the most impact on accountants is the change to MD&A that will allow issuers to exclude discussion of the earliest of three years in MD&A in a Form 10-K if they have already included the discussion in a prior EDGAR [Electronic Data Gathering, Analysis, and Retrieval] filing. This will remove one year of prior-period data on which auditors have traditionally been asked to provide comfort.”
June 2019
