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Comment Letter

SEC: Effectiveness of Financial Disclosures About Entities Other Than the Registrant

Wednesday, November 25, 2015

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In this comment letter, the CAQ provides observations and recommendations regarding the Securities and Exchange Commission’s consideration of the requirements in Regulation S-X applicable to certain entities other than the registrant. The CAQ offers suggestions regarding significance tests (Regulation S-X Rule 1-02(w)), financial statements of acquired or to-be-acquired businesses and real estate operations (Regulation S-X Rules 3-05 and 3-14, respectively), pro forma financial information requirements for acquisitions and dispositions (Regulation S-X Article 11), financial information of equity method investees (Regulation S-X Rules 3-09 and 4-08(g)), financial statements of guarantors or issuers of guaranteed securities registered or being registered (Regulation S-X Rule 3-10), financial statements of affiliates that collateralize registered securities (Regulation S-X Rule 3-16), and consideration of eXtensible Business Reporting Language (XBRL) tagging in other entity financial statements.