We support easing restrictions on communications during the offering process for larger seasoned issuers. We support the safe harbor for regularly released forward-looking information. However, we believe that limiting the scope of the exemption to the type of information that the issuer customarily released in the ordinary course of business during the past two fiscal years may discourage issuers from expanding the scope of forward-looking information. We gladly provide our investors free of charge copies of any publicly filed disclosure documents. An informed investor does not need a final prospectus to be delivered with confirmation of a sale.
Issuers take seriously their disclosure obligations and liability.
We believe that having an independent professional review the annual report would also increase issuers' costs without adding to the quality of such disclosure. We also are concerned about qualification standards for independent qualified professionals and the general availability of those meeting such standards. In both instances, the additional review and investigations would need to be performed while the issuer is gathering information and preparing the disclosure documents. The proposals appear to strive for more complete and thoughtful disclosure, in a more readable format, certified by more management and directors, and delivered to investors sooner. We support enhancement of the quality and timeliness of periodic reports.