SEC Shines a Spotlight on Short-Term Borrowings: Issues Guidance and Proposes New Disclosure Requirements
Client Memorandum

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On September 18, 2010, the SEC proposed amendments which would require both financial and nonfinancial companies to disclose additional information in registration statements and periodic reports about intra-period short-term borrowings.  At the same time, the SEC also issued interpretive guidance on existing liquidity and capital resource disclosure requirements, particularly with respect to short-term borrowings.