Now that we’re past the bulk of this season’s earnings, a view of how these disclosures get created is warranted. The points below don’t discuss what is in a release, but more who (internally) gets to participate in the workflow.
Additionally, although the timeframe of the process is not defined below, it begins the day after the previous quarter’s release is sent. You’ll certainly have a ton of “fresh input” and “constructive criticism” to consider.
Step one: IRO
The cycle begins with the Investor Relations department. That team will be responsible for directional navigation of the release and, of course, its complete execution.
- Drafting of initial messaging
- Define the overall “tone & tenor”
- Assemble all supportive data and documents
- Coordinate the editing and review workflow
Step two: Internal teams
These internal resources may supply the data and discussions to fill out the quarter’s narrative for shareholders.
- Sales management: important & material deals, sector & client perspectives, fee structure & macro-economic factors.
- Technology: R&D discussions, industry directions, technical descriptions.
- Product development: new product developments, marketing overview, peer and competitive discussions, strategic partnerships.
Step three: Subject Matter Experts
SMEs are in every internal and external publications from social media to marketing to investor relations.
- General Counsel / legal: assuring regulatory compliance for both the disclosure policy and the content itself including safe-harbor.
- Corporate communications & public relations: assuring alignment with overall communications plan and distribution, internal, external and needed crisis planning.
- Financial reporting and comptroller: confirming fiscal content and quarter to quarter reporting consistency, reconciling GAAP v non-GAAP.
Step four: The C-suite
This is a final “the buck stops here” review. Sarbanes-Oxley regulation has made the CEO and the CFO both personally responsible for the content: they both need to be 100% clear and confident on each word and number.
- They are signing a SEC document confirming their understanding.
Step five: IRO send to PR Newswire / Vintage
This goes without saying as this release needs to be sent with maximum efficacy and transparency to mitigate RegFD risk AND excite potential new investors.