Funding, Liquidity and Short-Term Borrowings: Time to Revisit MD&A Disclosure

23 September 2010
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This client memo discusses interpretive guidance issued by the SEC on September 17, 2010 about disclosure of liquidity and funding risks in Management's Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”). The client memo also discusses an SEC proposal made on the same date to require all registrants to make periodic disclosure with respect to short-term borrowings.