New Item 1a risk factors rules become effective Nov 9 2020

Here’s an overview:

•Require summary risk factor disclosure of no more than two pages if the risk factor section exceeds 15 pages

•Refine the principles-based approach of Item 105 by requiring disclosure of “material” risk factors (From “most significant” to “material”). This will result in risk factor disclosure that is more tailored to the particular facts and circumstances of each registrant which should reduce the disclosure of generic risk factors

•Require risk factors to be organized under relevant headings in addition to the subcaptions currently required, with any risk factors that may generally apply to an investment in securities disclosed at the end of the risk factor section under a separate caption (i.e., so a “general risk factors” section)