In 2019 and 2020, CorpFin modernized the process companies use to request confidential treatment.\u00a0 Prior to the modernization, companies essentially had to request and obtain permission from the staff to redact information from a filing.\u00a0 The modernized procedure allows companies to redact information in material contracts without specific staff approval if the information is immaterial and customarily and actually treated as private or confidential.\u00a0 This process is subject to staff review.\u00a0 While the new process is simpler for companies, the old process is still occasionally used today.<\/p>\n
On January 8, 2024, CorpFin updated sections of Disclosure Guidance Topic No. 7 related to confidential treatment applications pursuant to the old guidance, which is in Rules 406 and 24b-2.\u00a0 In an explanatory note CorpFin explains:<\/p>\n
This guidance has been generally updated, including with respect to options for confidential treatment orders that are about to expire. Different extension procedures apply depending on whether the order is greater or less than three years old. The prior version of this guidance referred to a fixed date rather than a rolling three-year period.<\/p>\n
You can find the updated Disclosure Guidance Topic here<\/a>.<\/p>\n As always, your thoughts and comments are welcome!<\/p>\n","protected":false},"excerpt":{"rendered":" In 2019 and 2020, CorpFin modernized the process companies use to request confidential treatment.\u00a0 Prior to the modernization, companies essentially had to request and obtain permission from the staff to redact information from a filing.\u00a0 The modernized procedure allows companies to redact information in material contracts without specific staff approval if the information is immaterial … Continue reading CorpFin Updates Disclosure Guidance for Certain Confidential Treatment Applications<\/span>