Subject: File Number S7-26-18
From: B. Mielke
Affiliation:

Dec. 18, 2018

Keep the light of Day

It is already enough that corporations insist on reporting and
highlighting NON-GAAP metrics, even despite numerous admonishments from
your organization.  This in addition to their already nontransparent
operational and reporting practices  (i.e. all of the incredibly small
fonts used in the various footnotes, or the footnote that consumes half
a page of the quarterly or annual statement) do not institutionalize
another layer of confusion to the system by reducing the quarterly
reporting requirement.

The average shareholder now only gets a very limited view into the
health of the company that is the basis of their investment.  Given the
quick reversal of fortune several large corporations have suffered
recently (GE), this reversal was not unexpected, and because of the
reporting requirements the management was forced to take action.

But with a reduction in internal for reporting required condition a
company’s finances could have been hidden until the company management
decided that the situation is untenable and late on a Friday afternoon
filed for relief via the courts.  Creating more chaos in an already
chaotic market.

The shareholder who is observant is presented information via quarterly
and annual SEC required reports that allowed us to make informed
decisions as to the suitability of our investments.  Please do not allow
the removal of the critical tool in the investment process.  Keep the
Quarterly Reporting requirements.

"If the broad light of day could be let in upon men’s actions, it would
purify them as the sun disinfects."  L. Brandeis