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

10 Pages Posted: 15 Jan 2016

See all articles by J. Robert Brown

J. Robert Brown

University of Denver Sturm College of Law

Joseph V. Carcello

University of Tennessee

Date Written: January 13, 2016

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.”

Suggested Citation

Brown, J. Robert and Carcello, Joseph V., Comment on SEC Release No. 33-9929, Effectiveness of Financial Disclosures About Entities Other than the Registrant (January 13, 2016). U Denver Legal Studies Research Paper No. 16-01. Available at SSRN: https://ssrn.com/abstract=2715103 or http://dx.doi.org/10.2139/ssrn.2715103

J. Robert Brown (Contact Author)

University of Denver Sturm College of Law ( email )

2255 E. Evans Avenue
Denver, CO 80208
United States

Joseph V. Carcello

University of Tennessee ( email )

Department of Accounting & Information Management
629 Stokely Management Center
Knoxville, TN 37996-0560
United States
865-974-1757 (Phone)
865-974-4631 (Fax)

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