April 21, 2022
I am in favor of the commission's proposed rules - in fact, truly I think every aspect of the proposed rules should be adopted. I appreciate the commission's efforts on this and I can only imagine that volume of work that went into this proposal from the open comment period last March through today. You should be commended and recognized for your efforts - this was an expectation from the commission and you delivered.
For the proposal itself, I think we need to transition from the \"old school\" way in which we measure a company's financial success and going concern - i.e., via the periodic filing of audited financial statements and supplemental disclosures - and start to envision a future in which a company's long-term value is based less on its current financial statements and more on its contribution to society at large.
I can understand the opposition to these proposed rules - i.e., more disclosure, more costs to implement - but at the same time, we need to collectively envision a different investing world - in which the investing community can invest their hard-earned money based less changes in revenue, cash flows, profits and more on long-term value impacting the triple bottom line (i.e., people, plant, profit).
In my opinion, financial disclosures (to say nothing about the complexity of the accounting) have become so cumbersome and unwieldly, that I cannot imagine they are as comprehensible to the average investor today as they were just a few short years ago. The volume of disclosures today has not correlated to the value that is added to the investing community (not to mention, I am of the belief that companies can get very \"creative\" in what they disclose and when - and still be within the GAAP guidelines).
I realize that this proposal would ADD more disclosure in the near term (despite my comments above), but I think its a very large step in the right direction and most importantly, its what the investment community wants and its what we need from the companies that we invest in.
Thanks for all that you do.