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Comment: SEC disclosure update and simplification

Today we submitted the attached comment letter to the Commission on its Proposed Rule on Disclosure Update and Simplification.

The objective of the Proposed Rule, which we supported and agreed with, is to simplify the disclosures in registrants’ financial statements by removing or amending the requirements that may have become redundant, duplicative, overlapping, outdated, or superseded in light of other Commission disclosure requirements, U.S. GAAP disclosure requirements, IFRS disclosure requirements, or changes in the information environment, without lessening the total mix of information provided to the investors. In addition the Proposed Rule also asked for feedback on certain disclosure requirements which could be referred to the FASB for incorporation in U.S. GAAP.