Request for Rulemaking to Require that Amended Registrant Filings Include an Explicit Summary of Specific Changes in Language or Figures
Scott H. Schulke
July 29, 2003
Jonathan G. Katz
re: Request for Rulemaking from General Public, Rule 192 (17CFR201.192)
Dear Mr. Katz:
I would like to petition for a new rule concerning certain amended filings made with the Securities Exchange Commission.
Many important SEC forms are lengthy and complex documents. It would be beneficial to all concerned if amended filings were required to have an explicit summary of the specific changes in language or figures at issue. This notification would explain in plain English, and in three to five sentences, the changes made in the amended filing compared with the original.
This notice of amendment section should be in a fixed location in the filing format, preferably inserted near the top of the form directly below the issuer name and address section, or directly after the indication of whether the registrant has filed all reports required by the SEC. This regulation should apply to amendments filed on all Form S-4, 10-K, 10-KSB, 10-Q, 10-QSB, 10K-405, 11-K, 20-F, 6-K and 8-Ks.
I noticed the need for this improved disclosure practice while working at a newswire that examines SEC filings for news value, although it would promote transparency of issuer disclosures for everyone who examines filings. I have spoken with others about this idea, and they believe it would be useful as well. My interest in this rule is to help improve the ability of the news media, investors and regulators to quickly and clearly identify the purpose of amended filings.
I appreciate your attention to this proposal.
Thank you very much.