Enhancement of Accommodations and Simplification of Filer Status (BDO Comment Letter)
BY ACCESSING THE FASB DOCUMENTS ON THIS SITE, YOU ACCEPT AND AGREE TO THESE FASB TERMS AND THE WEBSITE TERMS AS APPLIED TO YOUR USE OF THIS SITE OR ANY FASB LICENSED DOCUMENTS.
The SEC proposed amendments to simplify the filer status framework, extend scaled disclosure and reporting accommodations to all non-accelerated filers, and extend filing deadlines for certain small non-accelerated filers. Additional information about the proposal and its key provisions is available in BDO’s Bulletin, SEC Proposes to Simplify Filer Status and Extend Disclosure and Reporting Accommodations.
In our comment letter, we support the Commission's objective to simplify the filer status framework, reduce unnecessary complexity within the reporting system, promote capital formation and facilitate access to the public markets. We also provide observations on certain aspects of the proposal for which we believe additional analysis would be appropriate, including the filer status framework, internal controls over financial reporting attestation requirements, the proposed seasoning period for newly public companies, and the expansion of scaled disclosure and reporting accommodations.