Date: September 9, 2013

Issue: Corporate Governance

To: Securities and Exchange Commission

Filing Type: Regulatory

Description:  The CCMC believes that the dissemination of material information to investors is critical for efficient capital markets and the foundation of effective investor protection.  While the CCMC considers the final rule to be a reasonable approach to meeting these objectives, we are concerned that the proposed amendments could place additional burdens upon businesses that would interfere with legitimate efforts by small companies to raise investment capital, without materially improving the quality of investor protection.  In addition to questioning the merits of the proposed amendments we are especially troubled by its timing.  We believe strongly that the SEC should forebear from tinkering with the rule until it has had sufficient time to monitor its implementation and assess its impact.

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