CONCEPT RELEASE: BUSINESS AND FINANCIAL DISCLOSURE REQUIRED BY REGULATION

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264 Yes, failure to timely file 10-K and 10-Q could result in the disqualification for using the scaled disclosure. The time period is a year to cure this exclusion and regain this qualification

265 Actually public float criteria is the only criteria keeping public companies from inflating employee at will compensation package on paper

266 Scaled disclosure requirements are not called to help some larger companies, if SEC wants to reduce larger companies compliance costs, they will reduce all of them their compliance and administrative costs.

267 Information asymmetries between investors and managers of new companies are the highest because there is historical data of the companies. This sometimes has nothing to do with the size of the companies.

268 Yes, there are disclosure requirements for which scaling is not appropriate269 If an average investor needs a lot of information about the company in order to make an informed

investment and voting decisions.270 MD&A is very important for the SRC because of the discussion about revenues, liquidity and others. Market

price is not that necessary for SRC, the more data the market has about the company the more reliable the value it assigns to the company. When it comes to SRC, it is possible that there is not enough data to rely on. Asymmetric information balances in favor of the manager. That means sometimes the market undervalues the company because of its scaled disclosure. But, the company can reduce compliance and administrative costs thanks to scaled disclosures

271 SEC should consider scaling item 701 for the SRC. Item 404 needs to be revisited to restore related party disclosure. SRC and its managers acts too much and questionably with their related parties

272 EGC can take advantage of the scaled disclosure requirements currently available to SRC for elimination of backlog disclosure but we cannot eliminate tabular representation of contractual obligation, MD&A

273 No, this reorganization and separation of Reg S-K related to SRC will not provide new tool to the registrant and investor helping them to understand better the rules or/and disclosure or to make investment and voting decision

274 Definitely, we should not add unnecessary expensive data and pages nobody uses275 Based on good definition of materiality, all immaterial information should not be disclosed276 Sophisticated investors will be more affected by further scaling because they prefer a lot of data about the

company in order to make an informed investment and voting decision277 A good scaled disclosure’s costs and benefits analysis will indicate that SEC scaled disclosure reduce

compliance costs to the registrants. Scaling additional items requirements will reduce compliance costs to the registrant but with less information to the investing public, the market will undervalue the registrant. Like the 3rd world company, it is possible that the registrant shareholder will not be maximized. Can they disclose more voluntarily?

278 Yes, the investing public benefits 10-Q report. Big benefit is that it provides greater confidence and regular up to date information to investors who need reliance to trade shares between terms for wedding, funeral, donation to gifted children,… Quarterly report is here to stay

279 Because of consistency and comparability, the reporting requirements should be the same for all types of registrants. This quarterly reporting requirements should NOT exclude SRC

280 No, all categories of registrant should file quarterly financial report, I will find out the exception given to financial server companies

281 Filing a monthly report will be too expensive in term of compliance and administrative costs to any type of registrants

282 May be the 1st quarter needs some kind of scaled or abbreviated disclosure because of the Sch 14A report using some data of the 1st quarter. SEC should eliminate the requirement of information provided by Pre and Def 14A,… SRC should comply with scaled disclosure.

283 Quarterly reporting obligation plays a big role in the strategic goal and management of the registrant. I do not believe that quarterly reporting obligation hurts long term decision making of the registrant because its information helps the registrant to assess and monitor its long term projects

284 Both sophisticated investors and reasonable investors will value more 10-Q report as very good tools for investment and voting decision

285 I believe in the quarter report as good asset to preserve for regular valuation of companies, its projects and future plans. If we lose this tool, it will increase low confidence in the market valuation and asymmetric of information; it will reduce this frequent evaluation tool of the management and registrant performance and interest in the registrant’s management. For management, it is very necessary to know what your investors think about your management style and score regularly; do they have to wait for a year? Too long, investors will lose interests in registrants activities