Developments in Securities Regulation, Corporate Governance, Capital Markets, M&A and Other Topics of Interest. MORE

The SEC is requesting public comment on certain disclosure requirements in Regulation S-K relating to management, certain security holders, and corporate governance matters contained in Subpart 400. This request is part of the Division of Corporation Finance’s disclosure effectiveness initiative. Comments received in response to the request for comment will also be used in the SEC’s study on Regulation S-K, which is required by Section 72003 of the Fixing America’s Surface Transportation Act, or FAST Act.

The request is short, and does not ask for a lot of specifics. The request notes “[T]he purpose of this request for comment is to solicit public input on Subpart 400 of Regulation S-K, which requires certain disclosures about a registrant’s management, certain security holders, and corporate governance matters. The input can include comments on existing requirements in these rules as well as on potential disclosure issues that commenters believe the rules should address.”

John Jenkins holds the pen at while Broc Romanek is on an email free vacation. John notes “As Broc has blogged before, we have no idea why this is a “request for comment” – and not a “concept release” – but given the short length of the “request for comment,” the difference must allow the SEC to avoid the regulatory trappings of a full-blown concept release.”


Stinson Leonard Street LLP provides sophisticated transactional and litigation legal services to clients ranging from individuals and privately held enterprises to national and international public companies. As one of the 100 largest firms in the U.S., Stinson Leonard Street has offices in 14 cities, including Minneapolis, Mankato and St. Cloud, Minn.; Kansas City, St. Louis and Jefferson City, Mo.; Phoenix, Ariz.; Denver, Colo.; Washington, D.C.; Decatur, Ill.; Wichita and Overland Park, Kan.; Omaha, Neb.; and Bismarck, N.D.

The views expressed herein are the views of the blogger and not those of Stinson Leonard Street or any client.