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TCH Files Comment Letter Responding to SEC’s Regulation S-K

The Clearing House (TCH) has filed a comment letter responding to the SEC concept release regarding disclosure under Regulation S-K. TCH argues that: (i) Guide 3 should remain a guide and not a mandatory set of requirements; (ii) Guide 3 should be updated, as it has been several decades since meaningful changes have been made to it, and many of its suggested disclosures overlap with or are different from other disclosure requirements; and (iii) the SEC should work in close cooperation with other standard-setting authorities to develop a set of disclosure requirements that is complementary and not duplicative or inconsistent.