Overview
In our comment letter, we generally supported the proposed amendments, including the proposal to allow registrants that present three years of financial statements to omit from management’s discussion and analysis (MD&A) a discussion of the earliest year in certain circumstances. However, we suggested revisions to the two conditions the SEC proposed for registrants to omit a discussion of the earliest year. Further, we recommended that the SEC consider whether its use of a wide variety of references to materiality in Regulation S-K makes compliance unnecessarily complex.
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