Date: December 7, 2015

Issue: Accounting

To: Russ Golden, Chairman, Financial Accounting Standards Board

Filing Type: Regulatory

Description: CCMC supports the proposed amendments to the Exposure Draft on the Proposed Accounting Standards Update on Notes to Financial Statements (Topic 235) Assessing Whether Disclosures Are Material. We, likewise, support the provision in the Proposal to eliminate existing phrases in US-GAAP like “an entity shall at a minimum provide” and replace such phrases with less prescriptive language. As noted in the Proposal, such phrases would be an impediment to omitting immaterial disclosures.  CCMC also encourages FASB to avoid using the Proposal as a basis for promulgating expansive disclosure requirements down-the-road in future projects.

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