On August 26, 2020, the Securities and Exchange Commission adopted its previously proposed amendments to business, legal proceedings and risk factor disclosure requirements under Regulation S-K. Our Memorandum to Clients, published on August 12, 2019, summarized key aspects of the proposed rules. The amendments were adopted substantially as proposed with certain changes. The SEC approved the final amendments by a 3-to-2 vote, with Commissioners Lee and Crenshaw dissenting. Of note, the final amendments include a new requirement to disclose material “human capital” measures or objectives (if any). Over the objections of Commissioners Lee and Crenshaw, the amendments do not include any new requirements in respect of climate change risks. The amendments will become effective 30 days after publication in the Federal Register.
Subscribe to stay current on S&C Insights.
Sending an e-mail through this web site does not create an attorney-client relationship. You should not send us any information through this web site that you would want treated confidentially.