_and_quot;Real Time_and_quot; Disclosure 649



  • SOX is trying to increase transparency in a number of ways. One of those ways is by requiring ‘real time’ disclosure.
    I understand the terms real time and disclosure independently but I do not understand what this will literally translate to in practice.
    Could someone explain what the implications of this ‘real time’ disclosure will mean?
    Thanks in advance



  • Section 409 amends the 1934 Securities Exchange Act.
    Sec. 409. Real time issuer disclosures
    Each issuer shall disclose to the public on a rapid and current basis such additional information concerning material changes in the financial condition or operations of the issuer, in plain English, which may include trend and qualitative information and graphic presentations, as the Commission determines, by rule, is necessary or useful for the protection of investors and in the public interest
    So, the title of the section includes the phrase real time and the text the phrase on a rapid and current basis .
    What is rapid and current is actually not defined in SOX. It is sure that it is not quarters or months. Information must be disclosed as soon as it is discovered, not at a standard financial or annual report. When we have material changes in a company, the public has a ‘need to know’.
    Does rapid and current mean real time disclosure ?
    No. Vendors would love it, but no.



  • Thank you very much


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