Regulatory Alerts2023-09-12
SEC MC No. 13, Series of 2023 Guidelines on Annex C of Rule 12 of the Securities Regulation Code Interpreting the Comparative Periods Required in the Management’s Discussion and Analysis
The Securities and Exchange Commission issued this memorandum circular to resolve conflicting interpretations regarding the comparative periods required in the Management’s Discussion and Analysis of registration statements. The Commission clarified that the phrase 'for each of the last three fiscal years' mandates the disclosure of only two comparative periods rather than three. This interpretation applies prospectively to all registrants filing registration statements or other reportorial documents containing Management’s Discussion and Analysis.
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