SEC Proposes More Short-Term Borrowing Disclosures in MD&A

The SEC has proposed enhanced short-term borrowing disclosures, which are applicable to broker-dealers, publicly-registered investment advisers, and business development companies. The proposed rules involve changes to the MD&A disclosure in quarterly and annual reports to prevent end-of-period window dressing. The additional disclosure for each reporting period would include a computation of daily average amount outstanding, maximum outstanding during a reporting period, and weighted average interest rates. Separately, the SEC issued immediate interpretive guidance about liquidity disclosure.

OUR TAKE: The SEC continues its drive to increase financial statement transparency.

http://www.sec.gov/rules/proposed/2010/33-9143.pdf
http://www.sec.gov/rules/interp/2010/33-9144.pdf