SEC Request for Comment on Earnings Releases and Quarterly Reports
The Global Financial Institutions Accounting Committee
Summary
SIFMA’s Asset Management Accounting Policy Committee along with The Global Financial Institutions Accounting Committee as representatives of preparers of earnings releases and quarterly (and annual) reports, responded to the Securities and Exchange Commission Request for Comment on Earnings Releases and Quarterly Reports.
We support the Commission’s efforts to enhance the investor protection attributes of periodic disclosures and reduce associated administrative and other burdens on reporting companies.
We believe that the Commission should continue its efforts to modify the content of the Form 10-Q and to modernize the disclosure framework in order to reduce burdens on reporting companies without sacrificing investor protection.
Excerpt
Vanessa Countryman, Acting Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Re: File No. S7-26-18 Securities and Exchange Commission Release (No. 33-10588; 3484842): Request for Comment on Earnings Releases and Quarterly Reports
Dear Ms. Countryman,
The Global Financial Institutions Accounting Committee and the Asset Management Accounting Policy Committee of the Securities Industry and Financial Markets Association (“SIFMA”)1, as representatives of preparers of earnings releases and quarterly (and annual) reports, appreciate the opportunity to respond to the Securities and Exchange Commission (the “Commission”) Request for Comment on Earnings Releases and Quarterly Reports (Release No. 33-10588; 34-84842; File No. S7-26-18) (the “Request”). We support the Commission’s efforts to enhance the investor protection attributes of periodic disclosures and reduce associated administrative and other burdens on reporting companies.
Executive Summary
We believe that the Commission should continue its efforts to modify the content of the Form 10-Q and to modernize the disclosure framework in order to reduce burdens on reporting companies without sacrificing investor protection. Our main points with respect to the Request, which are discussed in further detail below, are as follows: