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Comment Letter

SEC: Disclosure Update and Simplification

Monday, October 3, 2016

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In this comment letter, the CAQ expresses its support for the Securities and Exchange Commission’s Disclosure Effectiveness Initiative, including its efforts in the Proposing Release to improve disclosures by amending certain requirements that may have become redundant, duplicative, overlapping, outdated, or superseded. The amendments will benefit investors, the CAQ says, by eliminating duplicative and outdated information thereby allowing the investor to better focus on the disclosure of material information. Additionally, these proposed changes will simplify the compliance efforts of preparers and their auditors.

The CAQ’s letter provides overall observations on the following topics:

  • Future Redundancies and Outdated Requirements
  • Interaction with the FASB Disclosure Framework Project
  • Disclosure Location Considerations
  • Legal Proceedings
  • Bright Line Disclosure Threshold Considerations
  • Smaller Reporting Company (SRC) Considerations

The letter also includes an appendix that provides observations regarding specific amendments included in the Proposing Release.