Category Archives: Industry news

Dōmo arigatō, Mr. (AP earnings reporter) Roboto

The Associated Press (AP) announced that they will be expanding their quarterly earning reporting from 300 companies to 4,400 companies by automating this banal and non-investigative journalism with “robots.”

AP_robot


From the AP:

For many years, we have been spending a lot of time crunching numbers and rewriting information from companies to publish approximately 300 earnings reports each quarter. We discovered that automation technology, from a company called Automated Insights, paired with data from Zacks Investment Research, would allow us to automate short stories – 150 to 300 words — about the earnings of companies in roughly the same time that it took our reporters.

Instead, our journalists will focus on reporting and writing stories about what the numbers mean and what gets said in earnings calls on the day of the release, identifying trends and finding exclusive stories we can publish at the time of the earnings reports.

What this means for issuers:

  • Expanded distribution from the AP: AP earnings articles are a formulaic synopsis of your formal earnings announcement. “Mr. Roboto” doubles your earnings’ content marketing towards investors, analysts and financial journalists who get feeds from the AP. In essence, the AP is treating your earnings as data rather than news.
  • Journalists more focused on stories: This is especially important for Emerging Growth and Small-cap companies. Many of these companies are Story Stocks, as their numbers are not so great (yet). The Human Journalists may have more availability and curiosity now for underdog and under-the-radar stocks. You could experience better ROI for your outreach efforts to the appropriate AP journalists. Get your story polished. 
  • What’s good for the goose is good for the gander: Issuers should have no fear of newsflow automation. Automate all banal distribution tasks. Here is a briefing on how you can automate your newsflow into Twitter and Stocktwits.

NOTE: The AP is not the only capital markets “reporting” organization to use robots. Resistance is futile.

Have a great day.

A brief “What Does CASL Mean for IR” blog post that does not constitute legal advice what-so-ever ipso facto

The Canadian Anti-Spam Law (CASL – pronounced “Castle”) goes into effect today, July 1, 2014. If you are in Canada or send electronic communications (email, IMs, Twitter direct messages) to Canadians, you’ll need to comply.

What does this mean for IR departments? Most likely, not a heck of a lot – especially if you have a commercially managed IR website (like our IR Room). You are already following the US CAN-SPAM guidelines by default.

Your email / opt-in procedure should already include:

  • The name of your organization and a description of the types of opt-in messages subscribers can expect to receive. For IR, this is your email alert opt-in system built within you IR site i.e. “I would like to receive a daily closing stock price.”
  • A statement informing individuals that they may withdraw (opt-out) their consent i.e “You can unsubscribe at any time.”
  • A functioning unsubscribe mechanism.
  • The mailing address and one of either a phone number/web address/email address of your organization.

That said, why is CASL being called the toughest SPAM law on the planet?

CASLThe difference between the US spam laws and Canada’s is actually deceiving simple.

In the US, it is opt-out legislation: you can (more or less) email contacts without legal retribution as long as you do not continue to email them AFTER they have unsubscribed. A “beg forgiveness rather than ask permission” model.

CASL is the opposite. It’s opt-in legislation: you cannot (commercially) email anyone without their appropriate consent BEFORE you hit the send button.

A simple example: you recently presented at an investor conference and the host organization gave you a contact list of all attendees. Your earnings call is next week and you would like to invite this group to the listen to the call. You may email the US-based contacts. The recipients may personally view your email as junk and alert “the internet” you are spam and get your email domain blacklisted (which is a drag), but that’s about it. However, if there are Canadian firms on the contact list, without documented express permission to email them - they have a binding legal right to ruin your day.

If you commit a violation under any of sections 6 to 9 of CASL, then you can be slapped with a steep administrative monetary penalty (AMP). The maximum amount of an AMP, per violation, for an individual is $1 million, and for a business, $10 million. Directors, officers and agents of a corporation can be liable too.

Fortunately, there is a three-year transition period, until July 1, 2017, to help companies adopt these new regulations. If you have more questions about CASL, contact an REAL CASL attorney who is familiar with this issue.

Realistically, the lionshare of IR departments will not have any trouble with CASL, as the technical opt-in process does mirror US CAN-SPAM. The trouble-spots will be around bulk uploading and emailing to new contact lists. You will need to be thoughtful about emailing contacts (in mass) from a IR targeting program.

Overall, the communications behavior of IR departments created no issues with the US CAN-SPAM Act, so the same professional IR work patterns should apply with CASL.

Emerging Growth and small-cap companies need to be a very aware to what their IR firms are doing on their behalf (coughcoughstockpromotioncough). Liability will trickle to all involved.

Bottomline, just don’t send “blast emails” to non-opt-in Canadian contacts. Official FAQs here: http://www.crtc.gc.ca/eng/com500/faq500.htm

Have a great day.

New Practice Group from Vintage Guides Clients with Shareholder Communications Solutions

“Corporate Services” brings intelligent value to investor relations at Emerging Growth and Small-cap companies

NEW YORK, June 27, 2014 / PR Newswire / — Vintage, a division of PR Newswire, today announced the expansion of their Vintage offerings to include Corporate Services, a practice area providing customized investor relations solutions for small-cap and emerging growth companies (EGC). The establishment of this new practice group within Vintage follows the company’s recent rebranding announcement.

The inclusion of investor relations services along with Vintage’s regulatory compliance services – IPO registration, XBRL, EDGAR and financial print – creates the industry’s first turnkey, intelligent value for public companies: beginning with their experience as a pre-IPO organization well into their maturity as a public equity.

PIGGY_BANKS_IRO_imbalanced5

Click to enlarge

According to a recent industry report from Rivel Research, small-cap companies spend 42% of their total investor relations budget with outside service providers, compared to the 18% allocation that large companies spend. For many smaller companies, the investor relations function is still viewed as a cost center and within these companies, whose average annual spend on external IR services is $130,000, budgets cuts are a constant concern. These financial pressures mandate that companies spend as intelligently as possible.

Vintage’s investor relations solutions cover multiple aspects of transparent shareholder communications, and are built to fit EGC, small- and mid-cap company requirements:

  • Investor relations websites
  • Earnings webcasting and conference calls
  • Media and news disclosure
  • Analyst-targeted distribution
  • Virtual Data Rooms
  • Rich media content creation
  • Annual report production and online distribution

“Emerging growth and small-cap companies have two related challenges – they are overlooked by Wall Street and underserved by the shareholder communications firms that support the industry,” said Liam Power, President of Vintage. “We’re helping our current Vintage regulatory compliance clients by bundling and integrating investor relations solutions into our Corporate Services practice, giving clients a toolset that can increase the presence of their financial brand while eliminating redundant, wasteful workflow tasks.”

One key example of the importance of shareholder communications, as reported in the 2014 “How Investors Consume Investor Relations Content” study, is that 70% of investors reported they will not take a position in a stock if the company does not have an investor relations website. “It is our goal to remove the barriers to capital for all our clients. For smaller companies, this includes offering a fee structure that is  balanced with their needs for shareholder communications,” continued Power. “That is how we define intelligent value.”

Vintage has released three new regulatory compliance and shareholder communications packages expressly for EGC and small-cap companies.

For detailed information:  http://www.thevintagegroup.com/contact-us/

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About Vintage

Vintage, a PR Newswire division, is a top-three provider of full-service regulatory compliance and shareholder communications services, delivered across our three practice areas: Capital Markets, Corporate Services and Institutional & Fund Services.

Founded in 2002 and acquired by PR Newswire in 2007, Vintage has evolved to become the industry’s intelligent value choice. We deliver a flexible balance of people, facilities and technology to ensure that regulatory compliance and shareholder communications processes are efficient, transparent and painless. Services include IPO registrations, transactions, virtual data rooms, EDGAR & XBRL filing, typesetting, financial printing and investor relations websites. www.thevintagegroup.com

About PR Newswire

PR Newswire (www.prnewswire.com) is the premier global provider of multimedia platforms that enable marketers, corporate communicators, sustainability officers, public affairs and investor relations officers to leverage content to engage with all their key audiences. Having pioneered the commercial news distribution industry 60 years ago, PR Newswire today provides end-to-end solutions to produce, optimize and target content — from rich media to online video to multimedia — and then distribute content and measure results across traditional, digital, mobile and social channels. Combining the world’s largest multi-channel, multi-cultural content distribution and optimization network with comprehensive workflow tools and platforms, PR Newswire enables the world’s enterprises to engage opportunity everywhere it exists. PR Newswire serves tens of thousands of clients from offices in the Americas, Europe, Middle East, Africa and the Asia-Pacific region, and is a UBM plc company. www.prnewswire.com

Media Contact:

Bradley H. Smith
Director of Marketing, IR and Compliance Services
PR Newswire & Vintage
+1 201.947.7157
bradley.smith@prnewswire.com

Vintage’s Evan Scharf Joins XBRL Dignitaries at White House Briefing

Last week, members of the Data Transparency Coalition had the honor of meeting (in the White House!) with the US Chief Technology Officer, Todd Park, to share their knowledge about XBRL and its upcoming role in the DATA Act.

Evan Scharf, Vice President of XBRL Services (far left) visits the West Wing with The Data Transparency Coalition members.

Evan Scharf, Vice President of XBRL Services (far left) visits the West Wing
with The Data Transparency Coalition members.

The DATA Act is the nation’s first legislative regulation for data transparency, mandating the uniform “tagging” of federal spending thus requiring the Department of the Treasury and the White House Office of Management and Budget to transform spending from disconnected documents into open, standardized data and to publish that data online.

Sound familiar? ( The answer is yes, it’s XBRL)

The group of XBRL industry leaders were invited to roundtable their expertise and insights on the implementation of accounting standards. Those of us working the corporate side of XBRL are keenly aware that success depends on focusing on what matters: the push for XBRL qualityCertainly, the DATA Act cements the overall (and continuing) economic drive for accounting standards and transparency.

At the meeting, key milestones were discussed to develop a blueprint that will establish common definitions of data elements that support reporting by governmental agencies plus provide foundation for the data’s taxonomy:

  • Establish Data Standards (data exchange) Team
  • Kick‐off planning meeting w/ contractor (detailed project plan, scope, and methodology)
  • Identify up to three pilot agencies (intelligent data)
  • Conduct pilot w/ Fiscal Service bureau‐level data to demonstrate data linkages & visualizations
  • Classify data elements and identify master data elements
  • Develop and map United States Standard General Ledger(USSGL) taxonomy and financial reporting taxonomy using XBRL
  • Consult with Industry
  • Develop reporting templates including business rules and validation templates
  • Complete agency pilots
  • Document and present the prototype pilot
  • Issue data exchange standards
  • Issue on standards (definitions) on Federal Funding Accountability and Transparency Act (FFATA) data elements
  • Establish concept of operations for data standards governance framework
  • Develop detailed agency roll‐out plan

Many thanks to The Data Transparency Coalition for Vintage’s presence in this important bipartisan path.

Have a great day.

Viva Las NIRI14 ! ( …and get ready to win your fabulous NIRI Conference souvenir)

The rebranding and redefining of Vintage is good news for public companies – especially for those looking for ( what we are calling ) intelligent value.

We’ve witnessed true growth of the cross-pollination between the shareholder communications and regulatory compliance functions within our clientbase. Sometimes this overlap is workflow-based, other times it’s been pure “purchasing power.” Regardless of their reasoning, clients have expressed satisfaction receiving an intelligent value.

Enough of that – let’s plan for the 2014 NIRI Annual Conference! Yay! 

NIRIsignWe’ll be meeting with clients and prospects to discuss…

  • …the new attributes and examples of our investor relations websites: click here to read of one example of what is new. Also, recently, our web developers have built some BEAUTIFUL custom sites. ( You’ll want to see those ) Plus, we’ve integrated our IR Room MST with The IRapp, the leader in…um… apps for IR. 
  • …IR & social media and our no-touch, no-risk approach to getting your news in the social news stream.
  • …news distribution and disclosure which is always a favorite topic! We have a staff of newswire experts in the booth who will answer your questions about distribution, tracking and maximizing value.
  • And of course, we want to hear about how your IR group interacts with your regulatory compliance group. Do you collaborate? How? When?

MOST IMPORTANTLY! 

Look for your purple pin in your NIRI Conference showbag. Wear it on your bag or lanyard and visit our booth #309. If your unique number (see the yellow arrow in the picture above) matches a number on our winners’ board you’ll win one of our 100 Fabulous VIVA LAS NIRI14 sweatshirts! ( Oh, don’t worry, the sweatshirts are NOT purple )

Have a great day and I will see you in Fabulous Las NIRI14! I mean Las Vegas! 

Companies Can Now Streamline IR Website Management & Improve Accuracy with Company-Verified XBRL Data

PR Newswire partners with Virtua Research to provide clients with ability to display balance sheet, income statement and cash flow data directly sourced from XBRL

NEW YORK, June 3, 2014 /PRNewswire/ — Investor relations departments can now ensure the release of accurate financial data on their website while also eliminating onerous and time-consuming processes with the announcement of a new partnership between PR Newswire and Virtua Research. The partnership seamlessly brings Virtua’s Interactive Analyst Center – the only product available today that delivers interactive, as-reported financial and operating data for IR websites – into the popular investor relations website solution, IR Room MST. Designed for investors and analysts, the Interactive Analyst Center makes company financial data more readily accessible and easier to understand online.

Virtua_logo_Signage

All IR Room MST clients can now publish their financial fundamental information directly from their own official SEC XBRL files. This eliminates the concerns issuers have long held regarding the inaccuracies of manually collected third-party financial fundamental data and delivering that data to their shareholders.

PR Newswire will be demonstrating IR Room MST with IAC at the National Investor Relations (NIRI) 2014 Annual Conference, June 8 – 11, 2014, in Las Vegas.

“Investor Relations Officers and CFOs have continually faced challenges with publishing unverified third-party financial information on their IR website,” said Bradley H. Smith, Director of Marketing for PR Newswire’s investor relations and compliance services. “While striving to be transparent in shareholder communications, using other data sources has opened the door for human error and forced IR departments to painstakingly double-check financial data, line-by-line. The IR Room MST with IAC uses the company’s own XBRL to eliminate that time-consuming task and seamlessly deliver company-verified reports online. It’s a wonderful example of the promise of XBRL realized.”

The use of XBRL with IR Room MST completes an end to end experience for clients that also use PR Newswire’s regulatory compliance division, Vintage, for the actual XBRL filing.

In addition to Virtua’s IAC, IR Room MST also includes three other elements – Mobile, Social and Targeting:

  • The IRapp™, the leading mobile app for a company’s investor relations content.
  • StockTwits IR for “hands-free” social media newsflow to the most socially engaged investors and financial portals.
  • Inbound Investor Targeting which uses content marketing methodologies to measure the effectiveness of IR outbound communications.

IR Room MST is available now as a complete investor relations website solution and as an upgrade package for all of PR Newswire’s current IR Room clients. For more information, visit: http://www.thevintagegroup.com/products/investor-relations-ir-websites.html

PR Newswire (www.prnewswire.com) is the premier global provider of multimedia platforms that enable marketers, corporate communicators, sustainability officers, public affairs and investor relations officers to leverage content to engage with all their key audiences. Having pioneered the commercial news distribution industry 60 years ago, PR Newswire today provides end-to-end solutions to produce, optimize and target content — from rich media to online video to multimedia — and then distribute content and measure results across traditional, digital, mobile and social channels. Combining the world’s largest multi-channel, multi-cultural content distribution and optimization network with comprehensive workflow tools and platforms, PR Newswire enables the world’s enterprises to engage opportunity everywhere it exists. PR Newswire serves tens of thousands of clients from offices in the Americas, Europe, Middle East, Africa and the Asia-Pacific region, and is a UBM plc company.

About Vintage Filings
PR Newswire’s Vintage Filings division is a full-service financial filing and printing firm and a leading partner for all your XBRL filing needs. With more than 4,500 public company clients, Vintage is one of the fastest growing compliance firms nationwide. Vintage partners with its clients to provide the knowledge and service necessary to meet the SEC’s ever-changing filing regulations. Vintage Filings provides high-quality, cost-effective compliance filings and production services, including EDGAR Filings, typesetting, XBRL tagging, section 16 filings, investment management services, drafting sessions, virtual data rooms (VDR) and more.
Contact
Bradley H Smith
Director of Marketing, IR and Compliance
PR Newswire
201 942 7157
bradley.smith@prnewswire.com

New York Attorney General announces unprecedented steps by PR Newswire to curb High Frequency Traders

On February 7, WSJ Financial Regulations reporter and author Scott Patterson broke the story Speed Traders Get an Edge: Paying for Direct Access to News Releases Can Give a Lucrative Time Advantage.

In this exposé, PR Newswire was identified as a newswire organization that does not sell to High Frequency (HFT) nor algorithmic trading firms. We believe this decision serves the best interests of both our corporate clients and the capital markets. The original story is available here for WSJ subscribers.

Today, as a follow up to the ongoing HFT issue, we’re pleased to share this important news from NY Attorney General Eric T. Schneiderman and an announcement from Ninan Chacko, CEO of PR Newswire.

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FOR IMMEDIATE RELEASE:

A.G. Schneiderman Announces Unprecedented Steps by News Distribution Firm to Curb Preferential Access for High Frequency Traders

Agreement With PR Newswire Is Latest Effort To Prevent Insider Trading 2.0, Practices That Result In Elite Traders Gaining Unfair Advantage Over Rest Of Market

Schneiderman: PR Newswire’s Industry-Leading Actions Help Restore Confidence In Markets And Protect The Investing Public

New York, April 30, 2014/PRNewswire/–Attorney General Eric T. Schneiderman today announced that PR Newswire, a leading news distribution and reporting firm, has agreed to require its direct data feed recipients to certify that they will not engage in high-frequency trading when using direct feeds of the information PR Newswire distributes on behalf of its clients. PR Newswire also agreed to counsel its customers that wish to release information upon the close of the markets to do so after 4:00:00 p.m., to ensure that high-frequency traders do not have the ability to trade on the news in the milliseconds after the closing bell. Today’s announcement follows agreements earlier this year between the Attorney General and Business Wire and Marketwired, each of which agreed to stop providing similar market-moving data to high-frequency traders.

“By going the extra mile to ensure its service is not abused by high frequency traders – at any time during the trading day and in the moments after  the closing bell – PR Newswire has proven itself to be an industry leader,” said Attorney General Schneiderman. “High frequency traders can use information in the milliseconds before it becomes widely available to other investors, effectively skimming from the rest of the investing public. Today’s agreement is another important step toward curbing Insider Trading 2.0, and PR Newswire deserves credit for its leadership.” 

PR Newswire provides an information distribution platform designed to help companies distribute press releases and other mandatory disclosures to the broad market. While PR Newswire had previously declined to provide its primary direct data feed to high-frequency traders, today’s agreement turns that practice into a formal policy at the company, and requires PR Newswire’s customers to certify annually that the direct data feeds they receive will not be used for high-frequency trading.

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As part of today’s agreement with the Office of the Attorney General, PR Newswire also adopted a first-in-the-industry policy to counsel clients to delay “4:00 p.m.” releases, which are intended to be released upon the close of the market, so as not to influence trading. Because certain securities exchanges, including NASDAQ, allow trading to continue for milliseconds beyond the 4:00 p.m. closing time, these close-of-market releases sometimes give high-frequency traders an edge that they can exploit in the milliseconds after 4:00 p.m.  Following discussions with the Office of the Attorney General, PR Newswire has adopted a policy to counsel clients that it is best to issue releases at 4:01 p.m., if the company’s intent is to make the release after the close of the markets.

Ninan Chacko, CEO of PR Newswire, said,

“Since our inception, we have taken a proactive approach to establishing practices that supply material news to investors and the general public equitably. Today’s steps solidify our industry-leading position promoting fair access to market-moving information.”

This agreement is part of Attorney General Schneiderman’s efforts to end Insider Trading 2.0 – the practice of providing preferred, technologically sophisticated traders with early access to market-moving information.  In March, Attorney General Schneiderman delivered a speech at New York Law School calling for regulators, stock exchanges, and other trading venues to curb arrangements that cater to high-frequency trading firms.  Last summer, Attorney General Schneiderman announced an agreement with Thomson Reuters to end its practice of selling early access to consumer confidence data to high-frequency traders.  Earlier this year, Attorney General Schneiderman also announced an agreement with BlackRock to end its global analyst survey program after an investigation revealed that a number of questions were worded to capture analysts’ unpublished views regarding management, competitive position, earnings, and other aspects of covered companies.  As part of that investigation, Attorney General Schneiderman announced that his office has secured interim agreements with 18 major financial firms to discontinue or to continue refraining from the practice of responding to such surveys and to continue their cooperation with the Attorney General’s investigation into the early release of analyst sentiment.

The Attorney General’s Insider Trading 2.0 initiative is led by the Office’s Investor Protection Bureau.

New York City Press Office / 212-416-8060
Albany Press Office / 518-473-5525
nyag.pressoffice@ag.ny.gov
Twitter: @AGSchneiderman

Source: New York State Office of the Attorney General

IPOs (and wanna-bes) met with Vintage Filings at NYSE event

NYSE Governance Services held a key East coast conference yesterday at their NYC HQ.

IPONYSEFrom the NYSE:

The Pre- and Post-IPO Board Forum will examine how corporate governance dictates success, providing participants an in-depth review of leading practices.

A series of panels will debate popular governance myths and realities and provide tips on building the most effective board, dealing with shareholders and institutional investors, and creating a roadmap to success in their new environment.

Obviously, we’re big into compliance and our presence brought an important “services execution” perspective to the NYSE’s attendees. In additional to understanding the strategic aspects of compliance, corporate leaders must have a tactical understanding of HOW to be compliant… beginning with the S-1.(download whitepaper here) That’s our role: pre-and post-IPO.

Topics included:

  • The IPO Landscape: A Global Perspective
  • Understanding and Implementing Core Regulatory & Governance Requirements
  • Myths and Realities of Shareholder Communications and Proxy Voting
  • The Board’s Role in the IPO Process
  • Governance Choices at the Foundation of High-Performing Boards
  • Best Practices for Engaging Your Shareholders
  • Board Composition
  • Ethics, Compliance, and Liability Considerations in the Public World
  • The Role of the Audit Committee Pre- and Post-IPO

Also, the NYSE distributed to all attendees our  Corporate Governance and Securities Laws handbook. Very useful. (request yours here)

PR Newswire / Vintage Filings was pleased to participate and we’re proud that our shareholder communications services are NYSE approved for their issuer and IPO program.

Have a great day.

Silicon Valley IPOs-to-be talk with our compliance experts-that-are

NYSE Governance Services held its West coast compliance readiness conference yesterday.

VF_NYSE

From the NYSE:

Preventing fraud in compliance with the Sarbanes-Oxley Act (SOX) and the Foreign Corrupt Practices Act (FCPA), as well as the importance of creating accurate financial statements and cooperating with internal audit in order to comply with the requirements of a stringent regulatory environment are just a few of the many challenges public companies need to communicate to their workforce.

Obviously, we’re big into compliance and our presence brought an important “services execution” perspective to the NYSE’s attendees. In additional to understanding the strategic aspects of compliance, corporate leaders must have a tactical understanding of HOW to be compliant… beginning with the S-1. (download whitepaper here) That’s our role: pre-and post-IPO.

Topics included:

  • The Nuts and Bolts of a Strong and Effective Compliance Program
  • Innovative Training and Communications Strategies
  • Leveraging Technology and Monitoring and Auditing
  • Emerging Compliance Risks

Also, the NYSE distributed to all attendees our  Corporate Governance and Securities Laws handbook. Very useful. (request yours here)

PR Newswire / Vintage Filings was pleased to participate and we’re proud that our shareholder communications services are NYSE approved for their issuer and IPO program.

Have a great day.

 

SEC disclosure reform: “Investors have a desire for more information, not less”

LESSLast week, the SEC’s Director of Corporation Finance, Keith Higgins, spoke to the Los Angeles’ chapter of American Bar Association. He revealed more insight and direction the disclosure reform initiative is taking.

At this point, the discussions are still at the strategic level of disclosure, not eliminating a particular filing group, but making sure the content disclosed is meaningful to investors.

  • What information do investors think is missing?
  • Is there information in existing mandated issuer disclosures investors routinely ignore?
  • Is there information in SEC filings investors routinely get elsewhere?
  • How can information be easier to access and used with on smart phones and smart pads?
  • Should disclosure requirements be tiered for different categories of issuers: smaller reporting companies or emerging growth companies?

Some of these questions are answered in the Shareholder Confidence 365 study here.

At the highest level, Mr. Higgins said investors have a desire for more information, not less. His staff’s job will be to find probable disclosure holes and make sure they are filled to the expectations of investors – all with actionable transparency in mind. Overload v. not germane.

For now, the only “tactile” point seems to pertain to the consideration of a “core disclosure” model: defined information that does not change often — such as a issuer’s business description, etc ­— would be disclosed in a “core” (annual?) document  with the K’s and Qs filling in the timely and current disclosures. This would slightly reduce “word-count” and bring some cost savings.

Have a great week.