SEC IAC Approves Market Structure Recommendations and Regulation S-K Concept Release (with Delta Strategy Group Summary)

Members of the SEC's Investor Advisory Committee ("IAC") unanimously approved (i) recommendations by the Market Structure Subcommittee to enhance information for bond market investors, and (ii) the SEC concept release regarding business and financial disclosure required by Regulation S-K.

The Market Structure Subcommittee's recommendations were intended to enhance disclosures to bond market investors, and included strong suggestions that the SEC work together with (i) the MSRB and FINRA to finalize markup/markdown rulemaking, since that information is unavailable to investors, (ii) brokers, FINRA and the MSRB to increase pre-trade transparency, and (iii) the MSRB and FINRA to continue improving easy access to price transparency in bond markets for retail investors. SEC Commissioner Michael S. Piwowar indicated that the IAC is focusing on shifting efforts toward greater pre-trade transparency.

In her opening speech at the meeting, SEC Chair Mary Jo White focused on the Registration S-K concept release. She emphasized the need for non-Generally Accepted Accounting Principles to comply with the compliance and disclosure obligations, and noted that presentation and delivery are critical aspects of fair and accurate disclosure.