Managing Information For SEC Disclosures

30 April 2007 Publication

Pharmaceutical Commerce

The SEC and the FDA have taken recent steps to enhance interagency cooperation, especially in the area of disclosure requirements. This move is significant since, in addition to scrutiny from government agencies, life science companies are often defendants in private securities class actions. In a recent article in Pharmaceutical Commerce, Foley partner Elizabeth Gray and Jessica Matelis of the Washington office discuss the impact of this enhanced relationship between the SEC and the FDA. The authors recommend that, given the closer agency relationship as well as the constant flow of information between life sciences companies and the FDA, and the frequency with which these companies raise public funds, the companies should develop and implement a robust set of disclosure policies and procedures to ensure that information is disclosed promptly and accurately.

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