Date: November 30, 2015
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.