Date: July 15, 2013

IssueAccounting and Auditing

To: International Integrated Reporting Council

Filing Type: Regulatory

Description:  The CCMC shares the IIRC‘s interest in overhauling the outdated public company reporting regime, in an effort to improve investors‘ access to information that they, the investors, believe is useful to their investment decisions. We believe it is critical that the concerns and considerations discussed above be addressed for the Framework to adequately address companies‘ and shareholders‘ legitimate investment information needs without adding further unnecessary complication to the public company reporting regime, making public company disclosures a forum for narrow interests, and potentially subjecting companies to liability.

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