Читать книгу Wiley GAAP: Financial Statement Disclosure Manual - Joanne M. Flood - Страница 104

In an April 2014 speech by Keith Higgins, SEC Division of Corporation Finance Director, Mr. Higgins suggested some ways that all entities can use to improve disclosure effectiveness. The highlights can be found below, and the full speech is available on sec.gov.

 Reduce Repetition:Think twice before repeating something.Consider using cross references.

 Focus Your Disclosure:Do not simply follow what others have done.Do not include a disclosure because it is a “hot button” issue. Consider whether it applies to the company.

 Eliminate Outdated Information: Disclosure should evolve over time. In a survey of 122 public companies, 74% said that once they include disclosure in a public filing in response to an SEC comment, it is rarely, if ever, removed.¹Companies and their representatives should regularly evaluate their disclosures to determine whether they are material to investors. If they are not material, and they are not required, take them out.Remove a disclosure when it is immaterial or outdated even if it was included in a prior filing in response to a staff comment. If it remains material, keep it in.

The full speech is available on sec.gov.