July 29, 2019
 

SEC: Amendments to Financial Disclosures about Acquired and Disposed Businesses

                         


Comment Letter

SEC: Amendments to Financial Disclosures about Acquired and Disposed Businesses

Monday, July 29, 2019

Download PDF

In this comment letter, the CAQ provides views to the Securities and Exchange Commission (SEC) on its Proposed Rule, Amendments to Financial Disclosures about Acquired and Disposed Businesses. The letter highlights potential improvements to the SEC proposal, with a focus on the following areas:

  • Overall Objective of the Proposed Rule
  • Significance Tests
  • Abbreviated Financial Statements
  • Independence
  • Foreign Businesses
  • Registration Statements
  • Financial Statements of Real Estate Operations Acquired or to be Acquired
  • Pro Forma Financial Information
  • Investment Company Considerations
  • SEC Staff Guidance