Nareit Responds to SEC Proposed Amendments to Disclosure Requirements

On April 28, Nareit submitted a comment letter in response to the SEC’s proposed amendments (Proposal) to certain financial disclosure requirements under Regulation S-K related to Management’s Discussion and Analysis (MD&A), Selected Financial Data, and Supplementary Financial Information.

The Proposal is part of the SEC’s Disclosure Effectiveness Initiative that is intended to modernize disclosure while reducing redundancy.

In the letter, Nareit supported key aspects of the Proposal:

  • Selected financial data – The Proposal would no longer require registrants to provide 5 years of selected financial data.
  • Supplementary financial information – The Proposal would no longer require registrants to provide 2 years of selected quarterly financial data.
  • Contractual obligations – The Proposal would no longer require registrants to provide a contractual obligations table.
  • Interim periods – The Proposal would permit registrants to compare their most recently completed quarter to either the corresponding quarter of the prior year or to the immediately preceding quarter.

(Contact: Chris Drula at

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