September 30, 2016
As a 75 year old private investor I have purchased shares of many companies in many industries over the years. When'd I was younger I enjoyed going over company reports, sec filings and reports from various services such as Value Line, Morningstar and others.
In my early days I naively thought that banks were almost a no brained. What could go wrong? Accept deposits, pay relatively low interest then loan the money out with prudent reserves at higher rates. Hard to fail at that game. But as I have learned is that greed regularly overcomes common sense and Directors CEOs and others throw small investors overboard because they are not material. The current standards of materiality are totally bogus from my viewpoint. The standard should be simply "How is this likely to be viewed by a small investor with thousands or millions invested. " It is wrongheaded to view this from the perspective of the company, say 5% of revenue or whatever. The SEC regulates companies not on behalf of the financial industry only but should make it a priority to consider materiality from the perspective of small investors like myself.
Thank you for the opportunity to comment.