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Comment Letter

Comment Letter to SEC on Proposed Changes to Regulation S-K

Tuesday, April 28, 2020

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The CAQ is generally supportive of the Security and Exchange Commission’s efforts to modernize, simplify and enhance the financial disclosure requirements in Regulation S-K and we appreciate the Commission’s thoughtful consideration of the input provided in our comment letter to SEC Release No. 33-10064, Business and Financial Disclosure Required by Regulation S-K (“previous comment letter”). We commend the Commission’s efforts to leverage technology and its consideration of changes in reporting requirements under U.S. Generally Accepted Accounting Principles (U.S. GAAP) and International Financial Reporting Standards (IFRS) in identifying and eliminating duplicative or redundant requirements. In that vein, we do not object to the elimination of Item 301, Selected Financial Data, and Item 302, Supplementary Financial Information. We also are supportive of the Commission’s efforts to modernize Regulation S-K using a principles-based approach. As stated in our previous comment letter, we believe this approach allows registrants to more effectively communicate material information to investors that is focused, relevant, and appropriate for a registrant’s particular facts and circumstances. Accordingly, we agree that clear and understandable disclosure objectives articulated within each item of Regulation S-K are important to define the parameters in which disclosures should be made.

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