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It supports the SEC’s integration objectives while urging reconsideration of shifting emphasis from Form 10-K to the annual shareholders’ report and concerns about legalistic boilerplate and directors’ personal liability.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/document/","Document",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/document/research-report/","Research & 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main purpose of the CCR’s comment letters in this report?","Question",{"text":63,"@type":64},"The Committee on Corporate Reporting issues comment letters responding to four SEC releases that propose major changes to securities disclosure requirements under the Securities Act and Exchange Act.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"Why does the CCR urge the SEC to reconsider its shift in regulatory emphasis?",{"text":68,"@type":64},"The CCR strongly urges reconsideration because using the annual report as the critical integrating document could turn it into a legalistic boilerplate and reduce the report’s effectiveness for readers.",{"name":70,"@type":61,"acceptedAnswer":71},"What concerns does the CCR raise regarding the SEC’s internal control and related proposals?",{"text":72,"@type":64},"The report states the SEC withdrew a proposed internal accounting control release, and highlights a three-year staff monitoring period and the emphasis on private sector initiative such as control documentation, auditor participation, and systematic effectiveness review.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},321863,1790508243,{"code":4,"msg":82,"data":83},"success",[84,88,92,96,101,106,111,115,120,123,126],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},"Story & Novel",90,"story-novel",{"id":26,"doc_module":4,"doc_module_name":25,"category_name":89,"show_sort_weight":90,"slug":91},"Literature",80,"literature",{"id":33,"doc_module":4,"doc_module_name":25,"category_name":93,"show_sort_weight":94,"slug":95},"Exam",70,"exam",{"id":97,"doc_module":4,"doc_module_name":25,"category_name":98,"show_sort_weight":99,"slug":100},5,"Comic",60,"comic",{"id":102,"doc_module":4,"doc_module_name":25,"category_name":103,"show_sort_weight":104,"slug":105},6,"Technology",50,"technology",{"id":107,"doc_module":4,"doc_module_name":25,"category_name":108,"show_sort_weight":109,"slug":110},7,"Healthcare",40,"healthcare",{"id":112,"doc_module":4,"doc_module_name":25,"category_name":29,"show_sort_weight":113,"slug":114},8,30,"research-report",{"id":116,"doc_module":4,"doc_module_name":25,"category_name":117,"show_sort_weight":118,"slug":119},9,"Religion & Spirituality",20,"religion-spirituality",{"id":118,"doc_module":4,"doc_module_name":25,"category_name":121,"show_sort_weight":118,"slug":122},"World Cup","world-cup",{"id":55,"doc_module":4,"doc_module_name":25,"category_name":124,"show_sort_weight":55,"slug":125},"Lifestyle","lifestyle",{"id":127,"doc_module":4,"doc_module_name":25,"category_name":128,"show_sort_weight":97,"slug":129},19,"General","general",{"code":4,"msg":82,"data":131},{"doc_id":79,"user_id":132,"nickname":42,"user_avatar":133,"doc_module":4,"category_id":112,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":97,"language":139,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":12,"update_tm":143,"read_time":144,"preview_page_count":4},1099514068035,"https://ap-avatar.wpscdn.com/davatar_276721f389ce27ea32af1340a28f341c","PUBLISHED BY FINANCIAL EXECUTIVES INSTITUTE,633 THIRD AVENUE,NEW YORK,NY 10017JULY 16,1980 NO.289  \n# CCR Comments on SECSubject Releases\n\nIn April,the Committee on Corporate Reporting issued twoletters of comment in response to the SEC's four releases thatpropose major changes to the Securities Act and ExchangeAct disclosure systems(see Alert,April 8 issue).  \nIn its first letter,referring to the proposed amendments toForm 10-K(33-6176),Regulation S-X(33-6178),and FinancialStatements(33-6179),the Committee states its generalsupport of the SEC's objectives to \"facilitate integration of thedisclosure system,eliminate differences between requirementsof Regulation S-X and GAAP and reduce the need to duplicateor repeat identical financial information in filings with theCommission.\"The CCR does,however,strongly urge the SECto reconsider ts change in regulatory emphasis from Form10-K to the annual shareholders'report.In this switch,theSEC proposes using the annual report as the critical integrat-ing document for a Securities Act filing,and mandates thatcertain expanded annual report disclosures be incorporated byreference in Form 10-K.The Committee expresses concernthat such a rule,if imposed,would turn the annual report intoa legalistic boiler plate,and would decrease the report'seffectiveness to its readers.It is also feared that the SEC'sadditional proposal to require directors'signatures on Form10-K will expose them to personal liability,not only forinformation contained in Form 10-K,but also for any data thatwould be incorporated by reference from the shareholders'report.  \nRegarding Regulation S-X,although the CCR commendsthe SEC for its efforts toward improving accounting disclosurerules,it does have several reservations:The proposed recon-ciliation of reported pre-tax income to federal taxable incomeand reported income tax expense to income tax shown on taxreturns would result in misleading information,if such areconciliation were even possible.For example,foreign andU.S.income and income taxes cannot be separated asprecisely as the SEC would mandate.  \nThe Committee endorses the SEC's effort to standardizeperiods covered by financial statements in various filings andregistrations under the Securities Act.Nevertheless,it doesobject to bringing the clutter of Regulation S-X into the annualreport of the shareholders,citing the risk of compromising thereadability of the final report.  \nIn a second letter regarding Release No.33-6177,\"Busi-  \nness Combination Transactions-Proposed Short Form for  \nRegistration and Proposed Amendments of Related Rules,\"the CCR noted that the use of the proposed Form S-15 wouldbe limited and would not,at least initially,significantly reducemerger costs.It also considers the proposal to incorporate byreference of the description of business from the shareholders'report into Form S-15 without limiting content to be inconsistent with Release 33-6176.This proposal would also appear tobroaden the liability of the registrant to all statements in thebusiness section of the annual report.The Committee suggeststhat this requirement be deleted,or that the language berevised to limit the business description.  \n# SEC Withdraws InternalControl Reporting Proposal\n\nThe Securities and Exchange Commission on May 28th,approved the staff recommendation to withdraw the proposedrelease No.15772,4/30/79,re Management Statement onInternal Accounting Control.  \nThe BNA Daily Report for Executives,No.104,includedthe following additional comment:  \n\"Financial Executives Institute,since 1978,has beenurging its members to take the lead in encouraging theinclusion of management reports in their companies'annual reports.The SEC staff noted that FEI membershave been complying with the Institute's request ingreater numbers every year.  \nThose companies which are already providing manage-ment statements on their internal controls are supplyingmuch the same information the SEC would have required,according to James Doyle,SEC Prac","cbCainIlJctRxxr6","https://ap.wps.com/l/cbCainIlJctRxxr6","pdf",1363279,"English","# CCR Comments on SEC Subject Releases\n## Proposed disclosure system changes and concerns\n## Regulation S-X reservations\n## Second comment letter on business combination transactions\n# SEC Withdraws Internal Control Reporting Proposal\n## Withdrawal background and additional executive comment\n## Future course of action emphasized","[{\"question\":\"What is the main purpose of the CCR’s comment letters in this report?\",\"answer\":\"The Committee on Corporate Reporting issues comment letters responding to four SEC releases that propose major changes to securities disclosure requirements under the Securities Act and Exchange Act.\"},{\"question\":\"Why does the CCR urge the SEC to reconsider its shift in regulatory emphasis?\",\"answer\":\"The CCR strongly urges reconsideration because using the annual report as the critical integrating document could turn it into a legalistic boilerplate and reduce the report’s effectiveness for readers.\"},{\"question\":\"What concerns does the CCR raise regarding the SEC’s internal control and related proposals?\",\"answer\":\"The report states the SEC withdrew a proposed internal accounting control release, and highlights a three-year staff monitoring period and the emphasis on private sector initiative such as control documentation, auditor participation, and systematic effectiveness review.\"}]","CCR Comments on SEC Subject Releases - July 16, 1980 - Corporate Reporting Committee | PDF",1789960450,13]