Comment Letter

SEC: Amendments to the Accelerated Filer and Large Accelerated Filer Definitions

Monday, July 29, 2019

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In this comment letter, the CAQ provides views to the Securities and Exchange Commission (SEC) on its Proposed Rule, Amendments to the Accelerated Filer and Large Accelerated Filer Definitions. The CAQ begins its letter by noting the three pillars of the SEC’s mission: (1) protecting investors; (2) maintaining fair, orderly, and efficient markets; and (3) facilitating capital formation. “This Proposal is intended to promote capital formation,” observes the letter, “and while we are supportive of this goal overall, we believe the amendments in the Proposed Rule may not have the intended benefits to capital formation and may weaken the other two pillars of the mission.” The CAQ’s letter, focused primarily on the requirement for an independent attestation of a public company’s internal control over financial reporting, urges the SEC to preserve the current accelerated filer definition.