Meaningful cautionary language should be meaningful

Before

Factors that could cause actual results to differ from those described in forward-looking statements include, but are not limited to:

• Changes in local, regional and international business, economic or political conditions in the regions that we operate or have significant assets;

• Our ability to effectively deal with an economic slowdown or other economic or market difficulty;

• Adverse changes in credit quality trends;

• Our ability to determine accurate values of certain assets and liabilities;

• Credit ratings assigned to Acme;

• Changes in investor sentiment, consumer spending or saving behavior;

• Our ability to manage liquidity, including anticipating interest rate changes correctly;

• Changes in trade, monetary and fiscal policies of various governmental bodies could affect the economic environment in which we operate;

• Changes in foreign exchange rates;

• Adequacy of our risk management program;

• Increased competitive pressure due to consolidation;

• New or heightened legal standards and regulatory requirements, practices or expectations;

• Our ability to timely and effectively implement our strategic initiatives;

• Increases in FDIC premiums and fees;

• Unanticipated adverse affects of acquisitions and dispositions of assets, business units or affiliates;

• Our ability to attract and/or retain key executives and/or relationship managers;

• Operational or risk management failures due to technological or other factors;

• Changes in accounting principles or in tax laws, rules and regulations;

• Adverse judicial proceedings; and

• Occurrence of natural or man-made disasters or conflicts or terrorist attacks disrupting the economy or our ability to operate.

Before, with commentary

My problem with all of these bullet points is that there are no definitive statements. The company mentions possible events, but doesn’t explain their implications. What might happen if there are “adverse changes in credit quality trends”? What should we know about the company’s “ability to manage liquidity”? These are boilerplate generalities, not the “meaningful cautionary language” the statute requires.

After

Although we cannot identify all the risks and uncertainties that may arise, here are some factors that could cause actual results to differ from those described in our forward-looking statements:

• There may be adverse or unexpected changes in local, regional, and international business, economic, or political conditions in the regions where we operate or have significant assets;

• We may be unable to effectively deal with an economic slowdown or other economic or market difficulty;

• Adverse changes in credit quality trends could hinder our lending operations;

• We may be unable to determine accurate values of certain assets and liabilities;

• Credit ratings assigned to Acme could decline;

• Changes in investor sentiment, consumer spending, or saving behavior could affect the market for our stock or the demand for our services;

• We may be unable to manage liquidity or anticipate interest rate changes correctly;

• Changes in trade, monetary, and fiscal policies of various governmental bodies could affect the economic environment in which we operate;

• Changes in foreign exchange rates could affect our overseas transactions in unexpected ways;

• Our risk management program may prove inadequate;

• We may face increased competitive pressure due to industry consolidation;

• We could become subject to new or heightened legal standards and regulatory requirements, practices, or expectations that management did not anticipate;

• We may be unable to timely and effectively implement our strategic initiatives;

• FDIC premiums and fees could increase;

• Acquisitions and dispositions of assets, business units, or affiliates could have adverse consequences that management did not anticipate;

• We may be unable to attract or retain key executives and relationship managers;

• We may suffer operational or risk management failures due to factors such as inadequate or ineffective technology;

• Changes in accounting principles or in tax laws, rules, and regulations may affect our business or the businesses of our customers in unexpected ways;

• We may be subject to adverse judicial proceedings; and

• Natural or man-made disasters or conflicts or terrorist attacks may disrupt the economy or our ability to operate.