Editors' Summary: Since the 1930s, the Securities and Exchange Commission (SEC) has imposed various disclosure obligations on companies that publicly offer securities. These disclosure requirements are intended to aid investors in making informed investment decisions. Beginning in 1971, the SEC has issued guidance and regulations concerning the circumstances under which companies must disclose environmental liabilities. This Article analyzes a recent SEC interpretive release concerning the disclosure required in Management's Discussion and Analysis of Financial Condition and Results of Operation (MD&A) in SEC filings. The authors analyze the significance of the MD&A Release to the disclosure of environmental liabilities. They conclude that the MD&A Release has increased management's burden in making disclosures and leaves several important issues unresolved. Companies may thus wish to perform more thorough environmental investigations in connection with SEC filings.