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SEC Proposes New Disclosure Rules Targeting Balance Sheet Window-Dressing and Issues New MD&A Guidance

September 22, 2010

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The SEC has proposed new disclosure rules with respect to short-term borrowings. The proposed disclosure requirements would be similar to requirements currently applicable only to bank holding companies. In addition, bank holding companies would be subject to stricter reporting requirements in respect of short-term borrowings. Concurrently, the SEC approved the issuance of new interpretive MD&A guidance relating to liquidity. These initiatives are a response in part to concerns over so-called "balance sheet window dressing."

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