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Show The National Enterprise, August 4, 1976 Page ten Corporate Disclosure: To Tell or Not to Tell? Continued From Page Three room for tolerance and require only whats meaningful in the i.e. informamarketplace tion that will allow a reasonable person to make an informed investment judge- ment.' The Commission is pondering the propriety of including in disclosure statements such issues as forecasts about the companys business, general economy and industry factors that relate to its opera-- . tions, environmental and other socially significant matters not traditionally considered of direct relevance to investment or shareholder voting decisions. For those who would like to contribute their viewpoints, below is a list of questions to be addressed in position statements to the Committee on Corporate Disclosure. They should be sent to Mary E. T. Beach, Staff Director, . Securities and Exchange Commission, 500 North Capitol Street, Washington D.C. 20549. ' The Enterprise invites interested parties to mail copies of their statements to ing the company's business operations? (Please consider 1. What should the objectives the legal liability and compeof a corporate disclosure titive problems associated with such a requirements, and system be? 2. How should the standard of whether such information should, be reviewed by materiality be defined the federal securities laws? auditors.) 3. Should the SEC require, 4. Should the SEC require corporate filings to set forth corporate filings to set forth more forward-lookin- g and more information regarding analytical information regard- - general economy and industry factors that relate to the companys business operations? (Please consider the possibility of requiring this information in a statistical andor analytical format.) 5. Should the SEC require corporate filings to contain more information regarding us for publication. environmental socially-significa- and other matters nt not traditionally considered of direct relevance to investment or shareholder voting decisions? (Please consider what criteria should be utilized by the SEC in determining which such information to require in corporate filings.) 6. Should the concept of differential disclosure be further incorporated into the federal securities laws, for example, by requiring SEC corporate filings to be bifurcated into summary and detailed portions with the portion containing an under-- . taking by the company to furnish at its expense the detailed portion to investors who request it? (Please consider the legal ; liability problems that may be associated with such a requirement, and the kinds of information that should be included in the summary portion of the respective filings.) 7. Should the SEC put more emphasis on the continuous reporting obligations of companies under the 1934' Act so that when a security offering is made under the 1933 Act, scctffakae . 1 the registration statement would incorporate by reference all documents oh file with the SEC and contain only data For further information please call James Barrett , Chairman. Area Code 208 356-4229. regarding the particular offering and such other information as is necessary to make the documents incorporated by reference not misleading? 8. What information does the SEC presently require in corporate filings that is not useful to investment or shareholder voting decisions? (You may wish to examine typical corporate filings such as a 10-Annual Report, Annual Report to Shareholders, Proxy Statement, 1933 Act Registration Statement and 10-- Quarterly Report, and mark those tions of the filings you do not consider useful to investment decisions and those sections you do not consider useful to shareholder voting decisions.) 9. A. What information not presently required in SEC corporate filings would be useful to investment decisions? B. What revisions could be made .to the disclosure re- quirements of the SEC proxy Continued on Page Twelve K Q First Lombard Corporation Investment Bankers Salt.Lake City Idaho Falls . ' |