InvestorsHub Logo

boston745

01/15/19 12:24 PM

#21858 RE: madg #21857

Did you think I made the number up?

Notably, however, the new interps do not include any version of the old interp under former Item 404(b), which permitted nondisclosure of transactions between a company and a third party with which a director was affiliated, even if the value of the transactions exceeded the threshold of $60,000 (now $120,000), as long as the relationship was solely a business relationship that did not afford the director any special benefits and the amount involved did not exceed five percent of either the company's or the third party's consolidated gross revenues (the disclosure threshold under former Item 404(b)).

boston745

01/15/19 12:26 PM

#21859 RE: madg #21857

No exceptions?

Instruction 7.a. to Item 404(a) provides an exception from disclosure for transactions where rates or charges are determined by competitive bids. To qualify for the exclusion, the procedure used must involve the formal procedures normally associated with competitive bidding situations, such as specifications established for the transaction being bid upon as well as indications of the basis upon which a bid was accepted.



There are exceptions and legal loopholes to every law.