Tag Archives: Disclosure

Disclosure Simplification: SEC Referral Prompts FASB to Seek GAAP Tweaks

Last August, when the SEC adopted its disclosure simplification rules, it referred to FASB certain Reg S-X & S-K line items that overlapped with GAAP but called for incremental disclosure, and asked FASB to consider incorporating those additional disclosure requirements … Continue reading

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Appeals Court Ruling in Case Involving Inadequate Disclosure by RIA May Have Significant Impact on Future SEC Enforcement Proceedings

A recent decision handed down by the DC Circuit Court of Appeals in a case involving SEC action against an adviser for failure to disclose material conflicts of interest provides potentially significant precedent for SEC enforcement proceedings going forward. See … Continue reading

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Donor Disclosure Update: New NJ Rule; Veto of NJ Proposed Statute; 9th Circuit Divided

New Jersey is the latest state to compel disclosure of significant donors in the wake of the federal government's decision to eliminate reporting to the IRS by tax-exempt organizations (other than 501(c)(3)s) of their significant donors. NJ Attorney General Gurbir… … Continue reading

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Journal article merited better disclosure of affiliation w/competing group, not a lawsuit

Board of Forensic Document Examiners, Inc. v. American Bar Ass’n, — F.3d —-, 2019 WL 1930310, No. 18-2653 (7th Cir. May 1, 2019)The Board of Forensic Document Examiners is a non-profit organization that certifies forensic document examiners (currently about 12), … Continue reading

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CMS Finalizes Regulations Requiring WAC Disclosure in TV Ads for Rx Drugs

By David C. Gibbons & Alan M. Kirschenbaum — The Centers for Medicare & Medicaid Services (CMS) has finalized its proposed rule requiring pharmaceutical manufacturers to disclose the Wholesale Acquisition Cost (WAC) in Direct-to-Consumer (DTC) television advertisements for certain prescription … Continue reading

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