On January 30, 2020, the US Securities and Exchange Commission provided guidance regarding the disclosure of key performance indicators and metrics used in the Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) section of SEC filings. This commission-level guidance, which reflects the SEC’s interpretation of existing MD&A requirements, becomes effective on the date of its publication in the Federal Register, which will make it applicable to annual reports on Form 10-K and Form 20-F that are currently being prepared. In addition, on January 24, 2020, the SEC’s Division of Corporation Finance issued three MD&A compliance and disclosure interpretations. This Legal Update provides further detail and notes practical considerations on these developments.
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