To the Securities and Exchange Commission: I am writing to express concern regarding the increasing volume of immaterial, boilerplate information required by Regulation S-K. The current "one-size-fits-all" approach to look-back periods and descriptive requirements has led to a proliferation of "disclosure noise" that increases compliance costs and legal fees without providing sophisticated or retail investors with actionable data. I propose comprehensive changes to the following items to refocus filings on materiality rather than exhaustive history: 1. Reverting Non-Intentional Look-Backs to Five Years (Item 401(f)) - The 2009 expansion of the look-back period from five to ten years for events like bankruptcy has reached a point of diminishing returns. A bankruptcy from nine years ago—often a result of market-wide cycles rather than individual incompetence—is rarely material to a director’s or officer's current fitness. By treating "financial misfortune" with the same 10-year weight as "intentional fraud," the Commission forces companies to include stale data that obscures more recent and relevant professional history. 2. Elimination of Legal and Regulatory Boilerplate - The current requirements for Risk Factors (Item 105) and Legal Proceedings (Item 103) have become exercises in defensive lawyering. Companies are incentivized to list every conceivable, remote risk to avoid litigation, resulting in 20+ page sections that investors routinely skip. • Recommendation: Strictly enforce the "concise" mandate and raise the threshold for disclosing litigation that does not pose a genuine threat to the company’s "going concern" status. Instead of requiring a summary for bloated risk sections, the Commission should address the root cause: the defensive necessity of including immaterial, generic risks to begin with. 3. Streamlining "Significant Employee" and Human Capital Disclosures - While human capital is important, the granular requirements to describe internal organizational structures and "significant employees" (who may not be executive officers) often result in the disclosure of proprietary team structures without providing financial insight. These sections frequently become "copy-paste" placeholders that add bulk but not value. 4. The Cost of "Disclosure Creep" - The cumulative effect of these requirements is a significant increase in lawyer hours and audit costs. When the SEC mandates a 10-year look-back for non-intentional acts, it creates a "compliance tax" that disproportionately affects smaller reporting companies. Furthermore, the sheer volume of these disclosures makes it harder for investors to find the "signal" (actual financial health) amidst the "noise" (historical biographies and hypothetical risks). Conclusion - The Commission should move toward a principles-based disclosure regime that trusts issuers to disclose what is truly material. Reducing the look-back for non-intentional acts to five years and curbing the requirement for exhaustive legal boilerplate would significantly improve the readability and utility of periodic reports. It would also be better to have a definitive reduced disclosure period when possible to avoid more added legal costs and confusion.