From: Jon Faulkner
Sent: July 11, 2016
Subject: SEC Proposes Amendments to Smaller Reporting Company Definition

Unless the SEC also changes the definition to remove the 404 audit requirements for firms up to $250 million in public float, the auditors will push back and say there is no cost savings.  Therefore, we encourage the SEC to also raise the threshold for 404(b) to conform to the new $250 million definition.  Most firms already do an integrated accounting approach that includes a complete controls review, they would just avoid the added legal liability of the second opinion, thus providing savings opportunities for  companies and lowering the cost of being public for smaller firms.


Jon Faulkner
The Dixie Group, Inc.