Financial Disclosure: SEC Issues Request for Comment on Regulation S-X Requirements Relating to Entities Other Than the Registrant

Sullivan & Cromwell LLP - October 12, 2015

On September 25, 2015, the SEC issued a release (the “Release”) seeking public comment regarding the financial disclosure requirements in Regulation S-X for certain entities other than the registrant.  The Release, which is part of the SEC’s Disclosure Effective Initiative, invites comment on four rules:

  • Rule 3-05, Financial Statements of Business Acquired or to be Acquired;
  • Rule 3-09, Separate Financial Statements of Subsidiaries Not Consolidated and 50 Percent or Less Owned Persons;
  • Rule 3-10, Financial Statements of Guarantors and Issuers of Guaranteed Securities Registered or Being Registered; and
  • Rule 3-16, Financial Statements of Affiliates Whose Securities Collateralize an Issue Registered or Being Registered.
The SEC also seeks comment on any other issues relating to financial information about entities, or portions of entities, other than the registrant.  Comments are due on November 30, 2015.