Would the proposed disclosure serve as a deterrent for improper accounting practices?
Response: We believe the quantitative benefits to the proposed rule are unknowable. Quite possibly, the overall effect from the increased disclosures could be negative if investors misinterpret or improperly rely upon such data. We also believe among the best deterrents to improper accounting practices are a strong system of internal controls, members of company management and boards of directors who possess a high level of personal integrity, and appropriate penalties for those who violate their fiduciary responsibilities. It’s questionable whether expanded disclosures related to critical accounting estimates would have helped prevent some of the recently publicized improper accounting practices if those expanded disclosures were not truthful and forthcoming. Potential cost of proposed rules • Question: What are the potential litigation and liability costs that would be associated with the proposed disclosure requirements? Response: With the very detailed discussions outlined in the p
