Melissa Pfeuffer is Capital Markets Business Development Practice Group Specialist at Mayer Brown LLP. This post is based on her Mayer Brown memorandum.
Prior to 2020, the last significant revisions to Regulation S-K were over 30 years ago. As modernization of the human capital disclosure requirements have caught up with the times, companies are faced with setting reporting precedents. See our previous post that provides an explanation of the Regulation S-K amendments.
How did companies respond to the SEC’s new human capital disclosure requirement? To answer this question, a new report published by Intelligize discusses the differences in hundreds of Forms 10-K filed by S&P 500 companies. With no two filings alike, analysis shows that companies seemed to build on each other as time progressed; earlier filings were shorter, and less-inclusive in their disclosures, while later filings were longer and more descriptive. The study sample in the report specifically focuses on Form 10-K filings made from November 2020 through March 2021. Varying in style and content, the filings examined were bucketed into three wide-ranging groups: