It started with the SEC’s MCDC initiative and Cease and Desist Orders, then it was the resulting enhanced scrutiny of underwriters and now it’s amendments to Rule 15c2-12. Each has further emphasized the importance of ensuring a complete understanding and management of disclosure obligations and having comprehensive polices and procedures.
The amendments to Rule 15c2-12 have refocused the spotlight on issuers and their policies, procedures and controls as well as their filing history and ongoing disclosure management. Our full article (link below) highlights what the market has learned since the MCDC initiative, discusses the Rule 15c2-12 amendments and identifies several resources for your consideration.