The impact of the financial crisis will affect virtually all aspects of a public company’s SEC disclosure. For most financial services companies, a complete rewrite of the company’s management’s discussion and analysis section (MD&A) of the annual report may be necessary. These companies, which were some of the hardest hit in the economic crisis, will have to take a fresh look at the SEC requirements in light of business and economic conditions facing their industry and the economy at large. For many, an expansive discussion of liquidity issues may be necessary.
Commenting on the preparation of 2008 disclosure, John White, the director of the SEC’s Division of Corporation Finance, indicated, “If there is a year when you are going to go back and basically write your MD&A from a clean slate … this has really got to be that year.”
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