In this letter, the CAQ provides input on the SEC's Proposed Rule, FAST Act Modernization and Simplification of Regulation S-K. Consistent with the Commission’s views, the CAQ believes that parts of Regulation S-K require amending to streamline disclosure requirements and modernize how users may access information by incorporating the use of technology. While agreeing with several of the proposed amendments, the CAQ encourages the Commission to improve the clarity of the disclosure objectives in each item of Regulation S-K as it continues to consider other possible rules to amend. The CAQ also expresses its view that the Proposed Rule may not fully consider the impact some of the proposed amendments, such as incorporation by reference and hyperlinks, would have on the auditor in complying with the auditing standards of the Public Company Accounting Oversight Board.
December 18, 2017