ANALYSIS: SEC Acts on MD&A, But Passes on Climate Disclosures

SEC Corporation Finance Director William Hinman wasn’t kidding when he told recent conference attendees that the Commission would issue a Management Discussion and Analysis release “very soon.” Two days later, the Commission proposed regulatory changes, along with guidance on the use of key performance indicators and metrics in MD&A.

I recently spoke with Jeffrey D. Karpf and Francesca L. Odell, partners in Cleary Gottlieb’s New York office, about the Commission actions and whether the proposed changes adequately balanced disclosure simplification with investor protection.

The proposals covering financial disclosures and the MD&A portion of public company financial statements may appear ...