CCMC supports the development of robust financial reporting systems and strong internal controls to promote efficient capital markets and capital formation. CCMC believes it is important for SEC to adopt a comprehensive approach to modernizing financial reporting policies that includes, in addition to stepped-up enforcement, increased communication and cooperation among regulators, standard setters and stakeholders. This will reinforce SEC's efforts to drive bad actors out of the marketplace, by eliminating the complexity and ambiguity on which they thrive. This letter outlines some of the issues and suggested solutions to improve financial reporting.

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