Comment on SEC Release No. 33-9929, Effectiveness of Financial Disclosures About Entities Other than the Registrant

Abstract

This letter comments on the SEC’s proposals to improve disclosure effectiveness by altering the requirements of Regulation S-X. In particular, the letter asserts that the practice of requiring the use of pro forma financial statements under Rule 3-05 should be altered in a manner that makes the financials more effective. This could be done by allowing management to make greater use of assumptions and estimates in developing the pro forma financial statements, thereby providing shareholders with an analysis of the acquisition as seen “through the eyes of management.”