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Comment Letter

SEC: Amendments to Smaller Reporting Company Definition

Tuesday, August 30, 2016

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In this joint letter, the CAQ and the Council of Institutional Investors (CII) comment on the Securities and Exchange Commission’s proposal, Amendments to Smaller Reporting Company Definition. The letter expresses the two organizations’ strong support for the SEC’s proposed amendment to the accelerated filer definition, which would maintain the current accelerated filer public float threshold. The letter also registers opposition to any amendments that would erode Section 404(b) or increase the accelerated filer public float threshold. The CAQ and CII believe that any amendment that erodes Section 404(b) would substantially impact the quality of financial reporting by public companies to the detriment of investors and our capital markets more generally.