ASA Releases Comments to SEC on Regulation S-K Reform

WASHINGTON – The American Securities Association (ASA) today released a letter sent to the Securities and Exchange Commission (SEC) in response to Chairman Atkins' request for information on reforming Regulation S-K, the Commission's core corporate disclosure framework.

"ASA supports Chairman Atkins for undertaking this long-overdue initiative which will improve the regulatory environment for public companies and benefit American investors," said ASA President and CEO Chris Iacovella. "Consistent with the Chairman's 'return to first principles' agenda, the most consequential reforms to Regulation S-K will not be those that add to the compliance burden, but those that have the courage to lift it for public companies and their investors."

In the letter, ASA called on the SEC to anchor any reform of Regulation S-K in the longstanding legal standard of materiality, eliminate outdated and duplicative disclosure requirements, and streamline the executive compensation disclosure framework. ASA specifically recommends that the SEC consolidate overlapping cybersecurity disclosure obligations, adopt page limits for compensation discussion and analysis, and extend a safe harbor for forward-looking risk factor disclosures to shield public companies from frivolous litigation. ASA also urges the Commission to allow companies to incorporate Form 8-K disclosures by reference into quarterly and annual reports to eliminate unnecessary repetition.

To read ASA's full letter, including a priority recommendations table, click here.

###

The American Securities Association (ASA) represents the retail and institutional capital markets interests of regional financial services firms who provide Main Street businesses with access to capital and advise hardworking Americans how to create and preserve wealth. ASA’s mission is to promote trust and confidence among investors, facilitate capital formation, and support efficient and competitively balanced capital markets. This mission advances financial independence, stimulates job creation, and increases prosperity. The ASA has a geographically diverse membership of almost one hundred members that spans the Heartland, Southwest, Southeast, Atlantic, and Pacific Northwest regions of the United States.