NCACPA has formally submitted a comment letter in response to the Securities and Exchange Commission’s (SEC) proposed rule on the Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies.
While supporting efforts to reduce unnecessary compliance burdens and facilitate capital formation, NCACPA urges the SEC to take a more targeted approach to filer-status reforms. The Association emphasizes that any changes should preserve investor protections, disclosure comparability, and the benefits of independent auditor attestation of internal control over financial reporting (ICFR).
The comment letter recommends narrowing the proposed expansion of ICFR attestation relief, limiting or tiering the proposed 60-month IPO on-ramp based on issuer size and complexity, and maintaining clear disclosure requirements that support informed investor decision-making. The letter also encourages the SEC to coordinate with standard setters and regulators to identify other opportunities to reduce burdens on smaller and newly public companies without compromising financial reporting quality.
You can read NCACPA’s comment letter submission here. If you have questions about this topic or other policy matters, please contact NCACPA Coordinator of Advocacy & Outreach Will Edmondson.