On November 19, 2020, the Securities and Exchange Commission adopted amendments to modernize, simplify and enhance disclosure requirements in Regulation S-K. The amendments are intended to eliminate duplicative disclosures and to focus on material information for the benefit of investors, while simplifying compliance efforts for registrants. The amendments, which were adopted substantially as proposed with certain modifications, reflect an ongoing, comprehensive evaluation of the existing disclosure requirements as well as comments received in response to the SEC’s January 2020 proposing release. Our Memorandum to Clients, published on February 5, 2020, summarized key aspects of the proposed rules. The amendments will become effective 30 days after publication in the Federal Register, and registrants will be required to apply the amended rules for their first fiscal year ending on or after the mandatory compliance date, which is the date that is 210 days after publication of the amendments in the Federal Register. For calendar year registrants, the rules will apply to annual reports for the year ending December 31, 2021. Registrants will be required to apply the amendments in a registration statement and prospectus that on its initial filing date is required to contain financial statements for a period on or after the mandatory compliance date. Prior to the mandatory compliance date, registrants may voluntarily elect to provide disclosure consistent with the final amendments at any time after the effective date, so long as they provide disclosure responsive to an amended item in its entirety.