SEC Releases C&DI Updates

The SEC’s Division of Corporation Finance has recently made updates to the following compliance and disclosure interpretations (C&DIs):

• Securities Act rules — Amends Question 114.05, and deletes Question 123.01, related to Form S-3.
• Regulation S-K — Makes minor reference change (from Question 123.01 to Question 114.05 — see the previous bullet) in Question 117.05 on whether Item 402 disclosure must be included in a registration statement before the statement can be declared effective.
• Exchange Act forms — Adds new Question 110.10 on the definition of “previously reported” with respect to whether disclosures regarding changes in a registrant’s certifying accountant are needed under Form 20-F. In addition, withdraws Section 113 (three questions) on Form F-SR.
• Securities Act rules — Revises Question 198.05 on an issue related to the interaction between filing a Form S-3ASR or Form S-3 and filing a Form 10-K.