• SEC Issues Proposed Rules for Disclosure of Off-Balance Sheet Obligations
  • May 15, 2003
  • Law Firm: Dechert LLP - Office
  • The SEC issued a release on November 4, 2002 proposing new rules governing disclosure of off-balance sheet transactions. The proposed rules, which are intended to implement Section 401(a) of the Sarbanes-Oxley Act of 2002, would require "disclosure of off-balance sheet transactions, arrangements, obligations (including contingent obligations), and other relationships of an issuer with unconsolidated entities or other persons that have, or may have, a material effect on financial condition, changes in financial condition, revenues or expenses, results of operations, liquidity, capital expenditures or capital resources." The new disclosure would be located in the "Management's Discussion and Analysis" section of an issuer's periodic reports under a separate sub-caption.