Comments on Proposed Rule: Financial Disclosures About Guarantors and Issuers of Guaranteed Securities and Affiliates Whose Securities Collateralize a Registrant's Securities

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from the Division of Corporation Finance regarding a October 22, 2019, conference call with representatives of Cravath, Swaine and Moore LLP
Meeting with SEC Officials Memorandum from the Division of Corporation Finance regarding a October 21, 2019, conference call with representatives of PricewaterhouseCoopers LLP
Meeting with SEC Officials Memorandum from the Division of Corporation Finance regarding a October 21, 2019, conference call with representatives of Shearman and Sterling LLP
Public Comment Rubin E. Buckholz, Chair, Federal Regulation of Securities Committee, Business Law Section, American Bar Association
Public Comment Cravath, Swaine & Moore LLP
Public Comment Aseel M. Rabie, Managing Director and Associate General Counsel, Securities Industry and Financial Markets Association
Public Comment BDO USA, LLP
Public Comment Campbell Pryde, President and CEO, XBRL US, Inc.
Public Comment David S. Huntington, Chair, Securities Regulation Committee, Association of the Bar of the City of New York
Public Comment Ernst & Young LLP
Public Comment John L. Merino, Corporate Vice President, Principal Accounting Officer, and Jennifer L. Johnson, Staff Vice President and Corporate Controller, FedEx
Public Comment KPMG LLP
Public Comment Leonard J. Gatti, Senior Advisor, Comcast Corporation
Public Comment Maya McReynolds, Senior Vice President, Corporate Finance and Chief Accounting Officer, Dell Technologies, Inc.
Public Comment Mick Homan, Chairman, Committee on Corporate Reporting, Financial Executives International
Public Comment Peter Osvaldik, SVP, Finance and Chief Accounting Officer, and Daniel J. Drobac, VP, Controller, T-Mobile US, Inc.
Public Comment Richard F. McMahon, Jr., Vice President, Edison Electric Institute, and Matthew Kim, Chair, Accounting Advisory Council, American Gas Association
Public Comment C. Donald Whitmire, Vice President and Controller, Financial Reportin, Freeport-McMoRan Inc.
Public Comment Sullivan & Cromwell LLP
Public Comment Tony M. Edwards, Executive Vice President & General Counsel, Nareit
Public Comment Deloitte & Touche LLP
Public Comment Jeffrey P. Mahoney, General Counsel, Council of Institutional Investors
Public Comment Joshua Ford Bonnie, Simpson Thacher & Bartlett LLP
Public Comment PricewaterhouseCoopers LLP
Public Comment Nate Carey, Vice President and Controller, Ball Corporation
Public Comment Ken D. Semelsberger, Senior Vice President and Controller, Eaton Corporation Plc
Public Comment Cynthia M. Fornelli, Executive Director, Center for Audit Quality
Public Comment Grant Thornton LLP
Public Comment John C. Eichler, Senior Vice President and Controller, Windstream Holdings, Onc.
Public Comment Karen Parkhill, Executive Vice President & Chief Financial Officer, and Mary Wilcox, Vice President & Chief Accounting Officer, Medtronic plc

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-19-18
Release Number
33-10526
34-83701
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