The 2023 Reporting Season: Recent SEC Guidance

Harvard Law School Forum on Corporate Governance

Brian V. Breheny Raquel Fox Joseph M. Yaffe

Partners Brian Breheny, Raquel Fox and Joseph Yaffe discuss the uptick in comment letters from the staff of the SEC’s Disclosure Review Program. The authors take a close look at the general areas of focus of staff comments, including:

  • Non-GAAP financial measures
  • MD&A
  • ESG disclosure controls
  • Insider trading
  • Cybersecurity