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ASA Commends SEC Efforts to Modernize Corporate Disclosure Process

We commend the Commission for prioritizing the modernization of our securities laws and eliminating outdated or duplicative regulations.

WASHINGTON – The American Securities Association (ASA) today submitted a comment letter to the Securities and Exchange Commission (SEC) commending the Commission for its efforts to modernize the corporate disclosure process in a way that helps more American small businesses go and stay public, maintain needed investor protections, and create greater opportunities for all Americans to prosper.

“We commend the Commission for prioritizing the modernization of our securities laws and eliminating outdated or duplicative regulations that impose unnecessary costs on public company issuers and Main Street investors,” ASA CEO Chris Iacovella wrote in the letter.

“In the eight decades since the securities laws were enacted, annual and quarterly reports as well as proxy statements filed by public companies have consistently grown in both length and complexity,” Iacovella wrote. “Issuers now spend an average of $2.5 million for initial compliance costs to complete an IPO, and $1.5 million annually once they are public. Since the year 2000, the average length of a 10-K filing for public companies has increased by nearly 30%.”

The Proposal – which is part of the Commission’s mandate under the Fixing America’s Surface Transportation (FAST) Act of 2015 – seeks to update public company disclosure requirements related to the description of business, legal proceedings, and risk factor disclosures. As the Proposal notes, many of these requirements have not been updated in years, despite the changes that have occurred to how businesses operate and the increasing role that technology plays in the way companies deliver goods and services to their customers.

ASA supports several key components of the Proposal, including the adoption of a more principles-based approach to certain disclosure requirements, the allowance for businesses to use hyperlinks regarding legal proceedings in order to cut down on duplication in disclosure documents, and the provisions that will help investors better navigate and understand risk factor disclosure.

To read the full letter to the SEC, click here.


ASA’s regional financial services companies work in communities across the country to create jobs, grow the economy, and increase prosperity for all Americans. The ASA exclusively represents the capital market and private client interests of its members and seeks to promote free market principles making it easier to access financial advice and capital. ASA members help Americans save for retirement, provide Main Street businesses with capital to grow, and advise hardworking Americans how to create and preserve wealth. For the latest updates follow @AmerSecurities and learn more at


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