Subject: comment, File No. S7-01-20
From: Dan Jamieson
Affiliation:

May 1, 2020


May 1, 2020

Re: Proposed Rule: Management’s Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information SEC Release Nos. 33-10750; 34-88093; IC-33795; File No. S7-01-20

Dear SEC,

As a small, long-term investor, I urge the Commission to refrain from removing information from corporate reports.

Overall, I concur with the detailed comments made by the CFA Institute.

I would echo the Institute in that having information in several sections and tables, even if redundant, is very helpful to investors. Searching through a 10-Q or 10-K is not a problem, no matter how large the file. I generally know what I'm looking for, and the prescriptive format of reports makes that task fairly easy.

In particular, the Selected Financial information sections, which shows basic data for five years, is very helpful to long-term investors. Wading through multiple reports from various years, and sorting through all the adjustments, is difficult. The five-year summary in one table is extremely helpful to get a longer term perspective on a company's performance.

Similarly, I do not support the proposal to eliminate the requirement of Item 302(a) to provide two years of selected quarterly financial data. Again, having this comparative information available is quite helpful.

The management discussion and analysis section, while helpful to get an overview of what a company does, generally lacks meaningful discussion about what is really causing a company to increase or decrease sales or costs. The SEC needs to enforce better disclosure.

Finally, I find it odd that corporate lobbying groups claim that providing information in the current formats is burdensome, since it requires little more than a cut-and-paste of data issuers already have.

Sincerely,
Dan Jamieson