Excerpt from Current Issues and Rulemaking Projects Outline Quarterly Update (March 31, 2001)
Cover Page Gatefold for Registered Public Offerings
In many registered public offerings, issuers choose to include text and/or artwork inside the front and back cover pages. Graphics depicting a registrant's products or services, or explaining how they are used, can be very helpful to investors – particularly when the products or services relate to a complex process or technical industry. In order to avoid significant re-printing costs, we will review proposed gatefold and other graphic presentations as soon as they are available. Most of our comments are based on the following staff concerns:
The gatefold for each registrant is unique, and we take into account all the information we have learned about the registrant and its industry when we review it. Sometimes the gatefolds for two different registrants seem similar at first glance, but they may raise significant staff concerns in one instance and not in the other, based on the unique facts of each registrant.
Registrants and underwriters can expedite staff review and reduce the number of staff comments if they keep in mind our concerns when they are preparing their gatefold and other graphic presentations.