MFA sent a letter to the Security and Exchange Commission (SEC) supporting effort to modernize Regulation S-K and recommends refocusing disclosure requirements on material, decision-useful information for investors. The letter argues that current rules are overly prescriptive and duplicative, and calls for a more principles-based, streamlined framework that reduces compliance burdens while preserving meaningful disclosure.
MFA requests that the Commission consider the following observations and recommendations:
- Potential public company disclosure reform should be governed by an overarching standard of materiality.
- Maintaining quarterly reporting of financial information is important to investors.
- Any expansion in the disclosure relief for smaller companies should reflect a balanced approach that considers not only the benefits to companies but also any attendant consequences.
- As the Commission is reconsidering the integrated disclosure framework generally, MFA encourages the SEC to consider updating its company filing and public disclosure systems and redoubling its efforts to safeguard information filed with it.
