Another MD&A "Heads-Up" From the SEC: Short-Term Liquidity and Funding Risks

(October 7, 2010, Weil Alert)

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In September, the SEC issued its second interpretive release of the year that emphasizes the importance of giving investors early warning of material risks facing their companies. The new guidance, which relates to disclosure of the liquidity and funding risks posed by short-term borrowing practices, is of immediate relevance to calendar year reporting companies preparing their third quarter Form 10-Qs. The Commission has also proposed expansive new line-item requirements for MD&A disclosure by non-financial as well as financial companies of intra-quarter fluctuations in their short-term borrowings and the related risks and uncertainties.