August 7, 2014
We support the SEC's initiative on disclosure effectiveness and are hopeful that it will lead to meaningful changes that will benefit both investors and preparers. If the Commission is looking for a few "quickhitters" in terms of reducing redundant information in the Form 10-K, we would recommend the following:
1. Eliminate the prior year in review requirement in the Management Discussion and Analysis. For example, in the 2013 10-K, the requirement to include an analysis of 2012 versus 2011 performance. This information is presented in detail and available in the prior year 10-K.
2. Eliminate the 2-yr quarterly information table, including the stock price information. Similar to the item above, this information has been previously reported and is available for investors.