Date: September 17, 2013

Issue:  Accounting

To: Financial Accounting Standards Board

Filing Type: Regulatory

Description: The CCMC believes the Proposal would increase financial reporting complexity and potentially expand legal liability for companies, management, boards of directors, and auditors. Such a change in liability profiles may achieve the opposite outcome than FASB has intended by promoting boilerplate disclosures and not giving investors more decision useful information.

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