You wouldn’t think the federal government would have much to teach Corporate America about plain English.
You wouldn’t think the federal government would have much to teach
Corporate America about plain English.
Think again. It’s been over a year since the US Securities and Exchange
Commission made straight talk the law of the land for public companies
with adoption of its ’Plain English Rule.’ And the busy bureaucrats in
the SEC Division of Corporation Finance have apparently seen their share
of bad writing in documents filed with the nation’s top corporate
We know this because, after wading through tens of thousands of
prospectuses and other documents subject to the new rule, the
bureaucrats have tapped out their own ’Guide to Bad Corporate
OK - so the bureaucrats lack the muse for such a name. Instead, in a
missive titled ’Updated Staff Legal Bulletin No. 7’
(http://www.sec.gov/offices/corpfin/cfslb7a.htm), the bureaucrats take
Corporate America to task, sharing some of the worst offenses against
’Now that the staff has gained several months’ experience issuing plain
English comments,’ Legal Bulletin No. 7 begins, ’we thought it would be
helpful to list the comments we have been issuing most frequently. By
alerting issuers to these comments before they file their next
registration statement, we hope to enable them to avoid receiving these
Let’s restate that in plain English: Read this bulletin before you file
with the SEC and before you risk corporate embarrassment (or CEO wrath)
for prose in your registration filings that is so confusing even a
trained team of bureaucrats would reject it.
The SEC Plain English Rule, adopted Oct. 1, 1998, has at its heart a
premise that should be dear to every public relations professional: the
best communication is clear communication.
Public relations professionals should adopt this same cause in the guise
of doing their job: Providing clear, consistent communication of the
strategic vision, priorities and (yes) financial results of the public
companies they serve.
What’s the risk of failing to apply the plain English test? The humbling
prospect of being edited at the hands of bureaucrats trained to hunt not
for misstatements of financial fact, but for ’short sentences,’
’definite, concrete, everyday language,’ and that favorite of high
school English teachers everywhere: ’active voice.’ So what’s a public
relations professional to do if he or she intends to avoid the federal
language police? Take a few pointers from the bureaucrats. Communicate
clearly. And talk to the folks in investor relations and legal about
- Paul Furiga is a vice president at Ketchum Pittsburgh