As companies prepare their annual reports on Form 10-K and Form 20-F for calendar year 2024, they should consider recent changes to the disclosure rules of the U.S. Securities and Exchange Commission (“SEC”) and the implications of certain recent developments in SEC enforcement activity and rulemaking. This memorandum summarizes these disclosure considerations and highlights key changes to SEC rules that will affect Form 10-K and Form 20-F filings this upcoming reporting season.