SEC Updates Form 10-K

The raucous team at the SEC rang in the New Year in the only way you'd expect them to: by publishing an updated Form-10K with minimal changes from the expired form. The prior form expired under its own terms on October 31, 2022. Please don't get too excited about the changes, because the changes are like the relative difference in spiciness between unsalted butter and double-whipping cream. With that, I'll add a SPOILER ALERT, in case you want to discover the changes for yourself. If not, read on...

The changes include:

• a reduction in the estimated average burden hours per response of about 70 hours: from 2326.62 hours on the expired form to 2,255.26 hours on the new form (I have no idea how this is calculated down to the hundredths of an hour, I only know that it must be true otherwise it could be materially misleading and there's no way the SEC is going to let THAT happen!);

• required disclosures regarding foreign issuers that use a variable-interest entity or similar structure (see Item 9C(b)); and

• clarification that supplemental information furnished by registrants with reports under Section 15(d) of the Exchange Act which have not registered securities under Section 12 of the Exchange Act must file their electronic filings in accordance with the EDGAR Filer Manual. Like you, I'm so relieved that the SEC has FINALLY brought clarity on this vexing issue.