MD&A quantification of variance drivers between reporting periods

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The staff pressed companies to quantify all factors cited as contributing to variances between periods in their annual and interim MD&A, rather than providing only qualitative descriptions. Referencing Regulation S-K Section III.D (Release No. 33-6835), the staff asked companies to describe underlying reasons for cited factors and quantify the dollar or percentage impact of each. This is a recurring MD&A disclosure quality theme.

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