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Comment: FASB proposal on accounting for certain financial instruments

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Today we submitted the attached comment letter to the FASB on their proposal on accounting for down round provision in certain financial instruments. The proposed Accounting Standards Update (ASU) is titled, Distinguishing Liabilities from Equity (Topic 480). Overall, we are supportive of the proposal, but believe this further complicates the accounting guidance in this area. Therefore, we have proposed an alternative to address this issue.