Key takeaways

• On June 27, 2016, the SEC proposed to expand the universe of companies that can benefit from scaled disclosure under both Regulations S-K and S-X by increasing the financial thresholds in the definition of “smaller reporting company."
• The amended definition of “smaller reporting company” would include companies with less than $250 million in public float, compared to the current $75 million threshold. For companies with no public float, the amended definition would include companies with annual revenues of less than $100 million, compared to the current $50 million threshold.
• The SEC has also requested comment on whether to increase the $75 million threshold in the “accelerated filer” definition that triggers both accelerated SEC reporting timelines and the Sarbanes Oxley 404(b) auditor attestation requirement.