PwC submitted its comments on the FASB’s proposal, Disclosure Improvements, Codification Amendments in Response to the SEC’s Disclosure Update and Simplification Initiative. We support the Board’s and SEC’s shared goal to streamline disclosures and remove redundancies between SEC disclosure requirements and US GAAP. We agree with the Board’s decision not to propose amendments for certain of the referred disclosures. Procedurally, we recommend the Board finalize the proposed amendments so that the SEC can then evaluate the disclosure requirements in Regulation S-X and Regulation S-K, and eliminate any duplication as part of its Disclosure Update and Simplification project. We generally agree with the FASB’s proposal, and in some cases recommended additional modifications.
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