From: James Edmond Smith
Sent: August 16, 2016
Subject: File Number S7-15-16, S7-16-15

1.) Modernizing certain business and financial disclosure requirements in Regulation S-K?.    I feel the requirement for these updates is necessary seeing that information on the internet can sometimes become vulnerable without individuals knowledge,but private and confidential should mean just that along with privacy policies data should be non useful to individuals, I feel that having so many position with the almost same reference to job is nice but should be within company relm.


2.) Commission disclosure requirements that overlap with, but require information incremental to, U.S. GAAP to determine whether to retain, modify, eliminate, or refer them to the FASB for potential incorporation into U.S. GAAP?. I would ask to retain,modify as little as possible as pool numbers need to be referenced and located upon request, other company changed information should be noted on all levels, updated materials unless noted prior to implementing changes or altering documents for security purposes should not be recognized which poses some but little issue seeing original never noticed, official documents should be sent direct with little searching needed a better secure way to transmit information pertaining to documents which need to be administered to others or for self copy.


3.) Commission disclosure requirements that overlap with, but require information incremental to, U.S. GAAP. As discussed in section III.E, we are not proposing amendments to this category of disclosure requirements in this release. Rather, the comments received in response to this release may inform both potential future Commission rulemaking and FASB standard-setting activities. I feel the information provided by both working commission and pay commission have been noted and will take into account amounts to be paid, working with 2 cpa's

4.) The proposed amendments are intended to facilitate the disclosure of information to investors, while simplifying compliance efforts, without significantly altering the total mix of information provided to investors?.The disclosures help others see what security flaws exist and what needs tobe done to fix it instructions were very straightforward not easy to remember but easy to understand, needing more help with infrastructure in USA.

1. Would the FASB's projects discussed above affect our: (1) Proposed amendments to eliminate certain Commission disclosure requirements due to a U.S. GAAP requirement or (2) potential referrals to the FASB of certain Commission disclosure requirements? YES  If so, how? EMAIL

2. Would the information provided to investors in the notes to the financial statements change if the source of the disclosure requirement (i.e., Commission rule or U.S. GAAP) changed? If so, how and why?I say no just harder to verify information needed, information needs to be verified by professionals and a person of contact should be able to be located if not one appointed according to last acct mngr 
3. Do the other proposed amendments within the FASB Exposure Draft related to notes to the financial statements  (57) impact the proposals made in this release? If so, how? No noted materials are referenced materials obvious and also verifies working before changes in 2016.

4. We solicit comment on the foregoing proposed amendments to eliminate redundant or duplicative requirements.

a. Do the requirements proposed for elimination require substantially the same disclosures as U.S. GAAP, IFRS, or other Commission disclosure requirements? yes. If eliminated, would investors continue to receive substantially the same information? Yes. If not, which redundant or duplicative requirements preliminarily identified above do not require substantially the same disclosures and why? Implementing privacy policies.

b. Should any proposed amendments not be made? Should any proposed amendments be modified? If so, which ones and why? Please be as specific as possible for each of the proposals on which you provide comments?.No,Yes modified confidential work documents need to be resent prior to 8or7/2013.

5. Are there other Commission disclosure requirements that are redundant or duplicative with U.S. GAAP, IFRS, or other Commission disclosure requirements that we should consider eliminating? If so, which requirements should be eliminated and how are they redundant or duplicative? no

comments by:James Edmond Smith/Sears Investment Inc.