Article
A Practical Fix For A Common MD&A SEC Comment?
The SEC frequently requests that companies quantify each material factor driving period-to-period changes in financial statement line items, yet this requirement often proves impracticable when factors are interrelated or not separately tracked. As the SEC reviews Regulation S-K for potential reforms, a simple textual amendment could resolve one of the most common MD&A compliance challenges by acknowledging when quantification is not reasonably available.
Barnes & Thornburg LLP