All findings and determinations made in carrying out the study.

Specific and detailed recommendations on modernizing and simplifying the requirements in Regulation S–K in a manner that reduces the costs and burdens on companies while still providing all material information.

Specific and detailed recommendations on ways to improve the readability and navigability of disclosure documents and to discourage repetition and the disclosure of immaterial information.

The SEC's work on the concept release on the business and financial disclosure required by Regulation S-K issued on April 13, 2016 (Concept Release) (see Legal Update, SEC Issues Concept Release on Modernizing Disclosure Requirements in Regulation S-K).

Public comments on the Concept Release.

The responses to the Request for Comment on Subpart 400 of Regulation S-K Disclosure Requirements Relating to Management, Certain Security Holders and Corporate Governance Matters (Subpart 400 of Regulation S-K) (see Legal Update, SEC Requests Comment on Disclosure Requirements of Subpart 400 of Regulation S-K).

The SEC's internal review of the history and development of Regulation S-K.

Proposed rules to modernize property disclosure for mining companies (see Legal Update, SEC Issues Proposed Rules to Modernize Property Disclosures for Mining Companies).

Proposed amendments to the definition of smaller reporting company (see Legal Update, SEC Proposes Amendments to Definition of Smaller Reporting Company).

Proposed amendments to certain disclosure requirements that may have become redundant, overlapping, outdated, or superseded, in light of other SEC disclosure requirements, US GAAP, IFRS, or changes in the information environment (see Legal Update, SEC Proposes Amendments to Update and Simplify Disclosure Requirements as Part of Overall Disclosure Effectiveness Review).

Proposed rules requiring hyperlinks to exhibits in filings (see Legal Update, SEC Proposed Rule Would Require Hyperlinks to Exhibits in Filings).

Revise Item 10(d) to permit incorporation by reference of documents that have been on file with the SEC for more than five years, but require specific descriptions of the locations of these documents and a hyperlink to the incorporated document on EDGAR. In limited circumstances, some registrants may need to re-file certain older exhibits that were originally filed prior to EDGAR.

Revise Item 10(d) to consolidate the SEC's rules on incorporation by reference and to allow registrants to satisfy Regulation S-K's disclosure requirements in prospectuses by incorporating information by reference to the financial statements. The SEC staff recognizes that cross-referencing disclosure provided outside of the financial statements within the financial statements may raise questions about the scope of an audit of a company's financial statements. To resolve this, the SEC staff recommends not permitting the use of incorporation by reference in the financial statements to disclosure found elsewhere.

Revise Item 102 (Description of Property) to clarify that a description of property is required only to the extent that physical properties are material to the registrant's business.

Revise Item 303(a) (Item 303: Management's Discussion and Analysis) to clarify that a registrant need only provide a period-to-period comparison for the two most recent fiscal years presented in the financial statement and may hyperlink to the prior year's annual report for the additional period-to-period comparison.

Revise Items 303(a)(1) and 303(a)(5) to eliminate the requirement to disclose a table of contractual obligations and instead require registrants to include a hyperlink to the relevant financial statement notes, while requiring additional narrative discussion of liquidity that describes material changes to contractual obligations and the ability to pay such obligations over time.

Clarify that Instruction 3 to Item 401(b) (Item 401: Directors, Executive Officers, Promoters and Control Persons) also applies to Item 401(e) by making it a general instruction to Item 401.

Revise Item 405(a) (Item 405: Compliance with Section 16(a) of the Exchange Act) to require registrants to rely solely on a review of Forms 3, 4, and 5, and amendments thereto (Section 16 reports), submitted on EDGAR instead of furnished under Rule 16a-3(e) when determining whether there are any Section 16 delinquencies that must be disclosed pursuant to Item 405. Because Section 16 reports must be filed electronically on EDGAR, eliminate the redundant requirement in Rule 16a-3(e) that reporting persons furnish them to the registrant.

Require registrants to include the Section 16(a) Beneficial Ownership Reporting Compliance section in their filings only if they have Section 16(a) delinquencies to report.

Revise the outdated auditing standard references in Item 407(d)(3) (Item 407: Corporate Governance).

Revise Item 407(e)(5) to clarify that emerging growth companies (EGCs) are not required to provide a compensation committee report.

Revise the instruction to Item 501(b)(1) (Item 501: Forepart of Registration Statement and Prospectus Cover Page) to eliminate the requirement for registrants to change their name in certain circumstances.

Revise Instruction 2 to Item 501(b)(3) to allow for the method of determining pricing to be disclosed elsewhere in the prospectus if a cross-reference is included on the cover page.

Revise Item 501(b)(4) to require disclosure of any national securities exchange where the registrant’s securities are listed or, if not listed, the principal US public trading market where such securities are quoted.

Reduce the length of the prospectus "subject to completion" legend set forth in Item 501(b)(10) by making the language regarding state law prohibitions optional when it does not apply to the offering.

Combine Item 501(b)(10) and (11) to address in one paragraph all the situations where the "subject to completion" legend is required.

Relocate "Risk Factors" from Item 503(c) to a new, separate item (Item 105) in Subpart 100 of Regulation S-K.

Clarify the application of the term "sub-underwriters" in Item 508(h) (Item 508: Plan of Distribution).

Eliminate the Item 512(c) (Item 512: Undertakings) requirement because it is duplicative and unnecessary.

Eliminate the Item 512(d), (e), and (f) undertakings because they are obsolete.

Revise Item 601 to require registrants to file a description of their securities as an exhibit to Form 10-K.

Permit the omission of attachments and schedules filed with exhibits, unless they contain information that is material to an investment decision that has not been disclosed otherwise.

Limit the two-year look back requirement in Item 601(b)(10(i) to newly reporting registrants.

Revise Item 601(b)(21) to require disclosure of legal entity identifiers (LEIs) for the registrant and within the list of significant subsidiaries. An LEI is a 20-characer, alpha-numeric code that connects to key reference information that allows for unique identification of entities in financial transactions.

Require machine-readable tagging of all of the information presented on the cover page of a registrant’s periodic and current reports.

Require the use of hyperlinks whenever the rules call for the inclusion of a web address, provided the appropriate technology is available to prevent such hyperlinks from jeopardizing the security and integrity of the EDGAR system.