In this letter, the CAQ notes the public company auditing profession's strong interest in the success of the Securities and Exchange Commission’s Disclosure Effectiveness Initiative. In the CAQ’s view, a principles-based disclosure regime, supplemented with guidance or considerations on how to apply the principles, will promote the disclosure of meaningful and relevant information. The CAQ also expresses its support a disclosure regime that can be consistently applied to all registrants. Different reporting requirements for differently-sized registrants may result in unnecessary confusion and complexity in the disclosure framework. The flexibility offered by such a framework should encourage registrants to tailor disclosures to their facts and circumstances and reduce redundant and overlapping disclosures. The CAQ encourages the Commission to conduct further extensive outreach and engagement with investors and other users of Commission filings to understand their views on how business and financial disclosures can be improved.
July 21, 2016