CFA Institute Comment Letter on the SEC’s Disclosure Effectiveness Initiative

Comment letter on disclosure effectiveness. The SEC has undertaken a review of disclosure effectiveness for US registrants and was expected to issue a concept release in 2014. In advance of the release of the concept release we submitted a letter to the SEC sharing our views on key elements of Regulations S-K and S-X as well as broader considerations the SEC should take into account when addressing the issue of disclosure effectiveness (e.g., technology, the change in the nature of users, how users access information, etc.).