Compliance
& Disclosure Interpretations Manual
CCH has recently published a convenient,
soft-cover version of the SEC’s compliance and disclosure interpretations
(C&DIs). A fully-integrated compilation of informal guidance from
the SEC’s Division of Corporation Finance, SEC Compliance &
Disclosure Interpretations reproduces the staff’s responses
to numerous inquiries about the statutes, rules and forms it administers.
These responses, previously known as “telephone interpretations,” serve
as an indicator of how the Division and the Commission itself might
proceed formally in various scenarios. After exhausting cases, releases
and no-action letters, practitioners often turn to this resource for
guidance.
The manual includes references
to the controlling authority (e.g., law section, rule, item, form),
as well as history notes indicating when the interpretation was issued,
modified and/or rescinded. Coverage includes new and revised interpretations
issued through September 14, 2009, e.g., new guidance on Regulation
13D-G, Regulation S-K, the Securities Act rules, Regulation S-T and
Form 8-K.
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