Subject: File No. S7-20-15
From: Frederick D. Lipman
Affiliation: Blank Rome LLP

December 4, 2015

To Whom It May Concern:

Sorry for the late comment.

Attached is my article from Insights magazine entitled “The SEC’s ‘Change the Sign’ Rule”, September 2011.  This “rule” clearly discriminates against smaller companies who purchase financial distressed businesses and must consider their losses as the numerator of a fraction to determine what is a “significant subsidiary” for purposes of SEC Regulation S-X 3-05.

Frederick D. Lipman | Blank Rome LLP
One Logan Square 130 North 18th Street | Philadelphia, PA 19103-6998


Copyrighted material redacted. Author cites:

Lipman, Frederick D. "The SEC's 'Change the Sign' Rule." Insights, Volume 25, Number 9, September 2011.