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NABL Releases Paper on Disclosure Policies and Procedures
The National Association of Bond Lawyers has released Crafting Disclosure Policies
, a paper to provide NABL members with tools to advise issuers in developing written disclosure policies and procedures. The paper explores the functions and benefits (as well as risks) of written disclosure policies, the subjects that drafters should consider addressing, and practical considerations for drafting such policies. The paper also includes a summary and discussion of relevant enforcement actions by the Securities and Exchange Commission (SEC). While recognizing that disclosure policies and procedures must be tailored to an issuer’s individual circumstances, structure, and characteristics, the paper also includes an annotated statement of policies and procedures. The annotated statement is not intended to be a recommended policy for any issuer. Rather, it is intended merely to illustrate the subjects and additional considerations that might be considered in formulating disclosure policies. In addition, sample disclosure policies may be found on the Securities Law and Disclosure Committee’s page on NABL’s website
. While many of these examples were prepared by NABL members, neither NABL nor its Board has approved or adopted a preferred template or form of disclosure policies. These examples are provided merely to assist counsel in understanding what other practitioners may have recommended and what issuers have adopted in their specific circumstances.