Tag: impact of inflation

In discussions of inflation, SEC staff want the details

According to a review of SEC staff comments by Bloomberg, Corp Fin staff have been weighing in to remind companies about the need to discuss, in SEC filings, the material impact of inflation—and don’t forget the details.  No doubt you remember that Item 303 of Reg S-K used to include an express requirement to discuss the impact of inflation and changing prices on net sales, revenues and income from continuing operations, but that provision was eliminated as part of the MD&A modernization project in 2020. (See this PubCo post.) Of course, at that point we hadn’t had any real inflation for years.  Then the SEC removed the explicit requirement and what do we have?  Inflation, of course—up to 9% in June 2022.