Date: November 30, 2015 

Issue: SEC

To: Brent J. Fields, Secretary, U.S. Securities and Exchange Commission

Filing Type: Regulatory

Description: the CCMC believes that any changes or updates to Regulation S-X should be based on four pillars:

1. Disclosures must be material and provide investors with decision useful information;

2. Significance tests under Regulation S-X should rely on revenue and fair value of common equity and other reporting thresholds should be based on materiality;

3. Synchronize the Securities Act’s financial statement age requirements with Exchange Act reporting deadlines and codify common Staff interpretive positions; and

4. Financial reporting standards and disclosures should reflect and not drive economic activity. Regulation S-X should not drive transaction structures.

Download PDF