NABL has released a paper entitled Crafting Disclosure Policies, to provide NABL members with tools to advise issuers in developing written disclosure policies and procedures.
The paper contains the following:
- An exploration of the functions and benefits (as well as risks) of written disclosure policies, the subjects that drafters should consider addressing, and practical considerations for drafting such policies.
- A summary and discussion of relevant enforcement actions by the SEC.
- An annotated statement of policies and procedures. The annotated statement is not intended to be a recommended policy for any issuer. Rather, it is intended merely to illustrate the subjects and additional considerations that might be considered in formulating disclosure policies.
- Sample disclosure policies, found on the Securities Law and Disclosure Committee’s page on NABL’s website.
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