Jay Clayton was nominated as SEC chairman and his nomination was approved by the Senate Banking Committee. In his confirmation hearing, he emphasized protecting investors and rooting out fraud. He also said the SEC should consider the economic effects of rules and conduct retrospective reviews. The Trump administration wants to ease some Dodd-Frank rules, and the SEC may provide relief from certain disclosure rules such as those around conflict minerals and pay ratios. Clayton said the SEC should consider whether disclosures provide material information to investors.

1. Clayton expected to be confirmed as SEC chair
Jay Clayton, a partner in the law firm Sullivan & Cromwell LLP, has been
nominated as chairman of the Securities and Exchange Commission
(SEC or the Commission). His nomination was approved by the Senate
Banking Committee and is expected to be confirmed by the full Senate.
In his opening statement at his confirmation hearing, Mr. Clayton said,
“All Americans should have the opportunity to participate in, and benefit
from, our capital markets on a fair basis, including being provided accurate
information about what they are buying when they invest.”
He added, “There is zero room for bad actors in our capital markets. I am
100 percent committed to rooting out any fraud and shady practices in our
financial system. I recognize that bad actors undermine the hard-earned confidence that is
essential to the efficient operation of our capital markets. I pledge to you and the American
people that I will show no favoritism to anyone.”
Mr. Clayton also observed, “In recent years, our markets have faced growing competition
from abroad. U.S.-listed IPOs by non-U.S. companies have slowed dramatically. More
significantly, it is clear that our public capital markets are less attractive to business than in
the past. As a result, investment opportunities for Main Street investors are more limited.
Here, I see meaningful room for improvement.”
In his testimony, Mr. Clayton said that, while the Jumpstart Our Business Startups Act (JOBS
Act) has made it easier for companies to go public, more needs to be done to make public
markets more attractive, particularly for medium-sized companies. One of his goals will be to
encourage private companies to undertake IPOs at earlier stages of their growth.
Issue 2, 6 April 2017
SEC in FocusQuarterly summary of current SEC activities
In this issue:
Clayton expected to be confirmed
as SEC chair ............................... 1
New push to ease SEC rules under
the Dodd-Frank Act .................... 2
SEC rulemaking and implementation. 3
Final rules on exhibit hyperlinks
and HTML format ..................... 3
Final rules on inflation
adjustments to EGC and
crowdfunding thresholds .......... 3
Proposed rule on Inline XBRL
filing of tagged data.................. 3
Possible changes to Industry
Guide 3 bank disclosure
requirements ........................... 4
Our feedback on the SEC’s
annual review under the
Regulatory Flexibility Act.......... 4
Recent updates to SEC staff
guidance..................................... 4
Compliance and Disclosure
Interpretations......................... 4
Other SEC activities....................... 5
Current practice matters ............... 6
Recent trends in SEC staff
comments................................ 6
SEC staff focus on SAB Topic 11.M
disclosures during filing reviews.. 6
2017 shareholder proposal
landscape................................. 7
2017 XBRL US GAAP taxonomy
available for use....................... 7
Securities markets......................... 7
Personnel changes......................... 8
Enforcement activities................... 8
Jay Clayton

2. EY AccountingLink | ey.com/us/accountinglink
2 | SEC in Focus Issue 2, 6 April 2017
In response to questions about whether companies should make disclosures about topics such
as political contributions, climate change or cybersecurity, Mr. Clayton said his touchstone for
disclosure is materiality: “What a reasonable investor would think is important.” He also noted
that shareholders can use the shareholder proposal process to seek those disclosures if desired.
In response to a question about the SEC’s rulemaking process, Mr. Clayton said considering
the economic effects of rules (both quantitatively and qualitatively) is an important aspect of
rulemaking. Mr. Clayton also emphasized the importance of rigorously performing a retrospective
review of the economic effects of rules. Mr. Clayton said that he believes SEC rules, including rules
mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act),
should be reviewed to assess whether they are effectively achieving their intended objectives.
New push to ease SEC rules under the Dodd-Frank Act
The Trump administration has signaled its intention to roll back regulations, including financial
regulations mandated by the 2010 Dodd-Frank Act, and directed executive agencies to review
their regulatory requirements.
Though the SEC is an independent agency and not bound to follow President Trump’s recent
executive order on deregulation, Acting SEC Chairman Michael Piwowar has asked the SEC
staff to consider whether relief is needed from the SEC’s conflict minerals and pay ratio rules.
Congress, meanwhile, has eliminated SEC rules that would have required disclosures of
payments made by resource extraction issuers to domestic and foreign governments for the
commercial development of oil, natural gas or minerals. These are among the 67 rules the
SEC adopted to fulfill Dodd-Frank Act mandates.
Speaking at the recent SEC Speaks conference hosted by the Practising Law Institute (PLI),
Mr. Piwowar said, “the Dodd-Frank Act is rife with examples of burdens ultimately borne by
the Forgotten Investor through shareholder money and company resources being expended
to provide non-material disclosures — the conflict minerals, pay ratio, and resource extraction
provisions to name a few.”
The SEC staff is currently reviewing comments the SEC received on the conflict minerals and
pay ratio rules. The Commission cannot revoke final rules that were mandated by Congress,
but it can amend final rules to provide additional relief. In addition, the SEC staff could provide
relief by issuing interpretive guidance.
The SEC’s final resource extraction payments rule was eliminated under the Congressional
Review Act (CRA), which allows recently finalized regulations to be overturned by a simple
majority vote in the House and Senate and approval by the president. The Dodd-Frank Act
mandate requiring the SEC to have such a disclosure rule still stands, however. Unless
Congress takes action to overturn that provision of the Dodd-Frank Act, the SEC is required to
propose a new resource extraction payments rule, although under the CRA, that new rule
must differ substantially from the rule repealed by Congress.
How we see it
Companies should closely monitor developments related to the conflict minerals and pay
ratio rules and the Dodd-Frank Act more broadly. Until the Commission or Congress acts,
however, companies need to comply with the SEC’s existing regulations.

3. EY AccountingLink | ey.com/us/accountinglink
3 | SEC in Focus Issue 2, 6 April 2017
SEC rulemaking and implementation
Final rules on exhibit hyperlinks and HTML format
The SEC adopted a final rule that will require registrants to include a hyperlink to each exhibit
listed in the exhibit index of nearly all filings subject to Item 601 of Regulation S-K as well as in
Form F-10 and Form 20-F filings. To enable the inclusion of such hyperlinks, the rule requires
registrants to submit such filings in HTML. The rule is effective 1 September 2017 for
accelerated filers and large accelerated filers and 1 September 2018 for smaller reporting
companies and non-accelerated filers.
Final rules on inflation adjustments to EGC and crowdfunding thresholds
The SEC amended the definition of an emerging growth company (EGC) to increase the annual
gross revenue threshold for new or existing EGCs to $1.07 billion from $1 billion to reflect
inflation as required by the JOBS Act every five years.
The final rule also makes inflation adjustments in the thresholds specified under the crowdfunding
rules for the maximum offering amount allowed in a 12-month period by a company, the
investment limits for individual investors and the financial statement requirements for offerings.
The final rule also amends the cover pages of various SEC forms (e.g., Forms S-1, S-3, 10-K, 10-Q,
20-F) to add check boxes for issuers to indicate whether, at the time of the filing, they are EGCs
and whether they have elected not to use the extended transition period relief available to EGCs
under the JOBS Act for complying with any new or revised financial accounting standards.
The rule is effective upon publication in the Federal Register.
Proposed rule on Inline XBRL filing of tagged data
The SEC proposed a rule that would require operating companies and mutual funds to use
Inline XBRL and embed tags in their financial statements and their risk/return summaries,
respectively, rather than provide this data in separate XBRL exhibits. The requirement would
be phased in over three years for operating companies based on their filing status and over
two years for mutual funds based on their net assets. As is the case for XBRL exhibits, officers
would not have to certify the Inline XBRL information, and companies would not need to
involve their auditors with the Inline XBRL information.
The proposal would not offer any exceptions. That is, it would apply to emerging growth
companies, smaller reporting companies and foreign private issuers that prepare financial
statements in accordance with IFRS as issued by the International Accounting Standards
Board (IASB).
The proposal does not suggest an effective date, but compliance under the phase-in schedule
would begin one year after the rule’s effective date. Comments are due by 16 May 2017.
In a related development, the SEC published an IFRS Taxonomy. Foreign private issuers that
prepare financial statements in accordance with IFRS as issued by the IASB are required to file
XBRL-tagged financial statements in annual reports for fiscal periods ending on or after
15 December 2017.
How we see it
If the rule is finalized as proposed, foreign private issuers that will have to begin filing XBRL
data should consider voluntarily using Inline XBRL in their initial submissions to avoid the
cost of changing from XBRL exhibits to Inline XBRL when it becomes mandatory.
EY resources
► To the Point, SEC proposes
requiring the use of Inline XBRL
(SCORE No. 00974-171US)

4. EY AccountingLink | ey.com/us/accountinglink
4 | SEC in Focus Issue 2, 6 April 2017
Possible changes to Industry Guide 3 bank disclosure requirements
The SEC is seeking public comment on statistical and other disclosures required by Industry
Guide 3, Statistical Disclosure by Bank Holding Companies. The request seeks comment on
potential improvements to the disclosure regime, including consideration of overlaps with
US GAAP and other regulatory requirements. Comments are due by 7 May 2017.
Our feedback on the SEC’s annual review under the Regulatory Flexibility Act
In our comment letter on the SEC’s periodic review of final rules that have a significant
economic effect on most small entities, we recommended that the Commission consider
making its review more transparent and more robust to encourage broader and more
meaningful participation by constituents.
The reviews, which are required by the Regulatory Flexibility Act (RFA), are intended to
assess whether rules should be revised or rescinded or whether they should remain in effect.
The RFA requires that a review be performed within 10 years of a final rule’s publication.
We believe an effective post-implementation review process should determine whether a rule
has accomplished its objective, evaluate the compliance cost for all issuers and the benefits
for investors, and inform and improve the rulemaking process.
Recent updates to SEC staff guidance
Compliance and Disclosure Interpretations
Form 20-F:
The SEC staff issued Compliance and Disclosure Interpretations (C&DIs) to clarify that:
• A foreign private issuer (FPI) may use an F-Series registration statement when it guarantees
securities of non-FPI subsidiaries or issues securities guaranteed by non-FPI subsidiaries.
The FPI may use Form 20-F with respect to any reporting obligations associated with that
registration statement if certain requirements of Rule 3-10 of Regulation S-X are met.
• A wholly owned subsidiary of an FPI may omit certain information from its Form 20-F annual
report if it meets the requirements in General Instruction I to Form 10-K, in the same manner
that a wholly owned subsidiary may omit certain information from a Form 10-K.
• An FPI’s annual report on Form 20-F is due on the last day of the fourth month after its
fiscal year end if its fiscal year ends on the last day of a month. If an FPI’s fiscal year ends
on a date other than the last day of the month, its Form 20-F annual report is due on the
same date four months after its fiscal year end.
• An FPI may incorporate by reference into a Form 20-F annual report information that was
previously filed on Form 6-K.
Regulation A:
The SEC staff issued C&DIs to clarify that:
• The staff will not object if a Regulation A issuer does not include an auditor’s consent to
use its auditor’s report on the financial statements in Form 1-K.
• An issuer of a Regulation A Tier 2 offering may follow the age of financial statements
requirements specified in paragraph (b)(3)-(4) of Part F/S of Form 1-A, which permit
the annual financial statements to be up to nine months old before requiring interim
financial statements.
EY resources
► EY Comments — SEC’s annual
review under the Regulatory
Flexibility Act
(SCORE No. CL00260-171US)

5. EY AccountingLink | ey.com/us/accountinglink
5 | SEC in Focus Issue 2, 6 April 2017
Other SEC activities
SEC Advisory Committee recommends board diversity disclosures
The SEC’s Advisory Committee on Small and Emerging Companies (ACSEC) approved a
recommendation that the Commission require issuers to disclose the race, gender and
ethnicity of each board member and nominee to the board. ACSEC recommended allowing
issuers to report the information board members and nominees use to describe themselves.
Current proxy rules require companies to disclose how diversity is considered in identifying
and evaluating director nominees, but the SEC does not require companies to disclose
diversity information about board members and nominees.
CAQ SEC Regulations Committee meeting
The Center for Audit Quality (CAQ) SEC Regulations Committee met with SEC staff on
23 March 2017 and discussed topics that included the staff’s views on:
• Disclosures included in recent annual reports about the pending effects of new accounting
standards on the financial statements, as well as developments related to disclosures of
non-GAAP financial measures
• The effects of accounting changes by a successor entity on the predecessor period
financial statements
• The effective date for adoption of Accounting Standards Codification (ASC) 606, Revenue
from Contracts with Customers, for an emerging growth company (EGC) that elected
private company adoption dates and then ceases to qualify as an EGC
Meeting highlights will be released in the second quarter.
Remarks at the PLI’s SEC Speaks conference
In his remarks at the SEC Speaks conference, Mr. Piwowar said he believes the SEC should no
longer distinguish between “accredited investors” who can purchase securities that are
exempt from the SEC registration requirements and non-accredited investors who can’t make
these purchases. He said the current requirements limit opportunities for non-accredited
investors to earn high returns and diversify their investments.
Commissioner Kara Stein highlighted some of the more significant changes in the capital
markets and said the Commission needs to address new challenges to protect investors.
“We need to assess whether our current [regulatory] structure is sufficient to withstand the
changes we face,” she said. “Are there better ways for us to address the challenges of a
computerized market? Are anti-manipulation laws passed in an era of floor trading sufficient
for an electronic marketplace? Do these laws need to be amended?” Ms. Stein also stressed
that the Commission should not rush to eliminate disclosures but should embrace the chance
to use technology to improve them.
The SEC staff from the Office of the Chief Accountant (OCA) and Division of Corporation
Finance participated in a panel discussion and shared views similar to those the staff
discussed at the 2016 AICPA National Conference on Current SEC and PCAOB Developments
on the implementation of significant new accounting standards, related transition disclosures
and non-GAAP measures, among other topics.
Chief Accountant Bricker discusses the effectiveness of audit committees
In a recent speech, SEC Chief Accountant Wesley Bricker said audit committees “play a critical
role in contributing to financial statement credibility through their oversight and resulting
impact on the integrity of a company’s culture and internal control over financial reporting.”
EY resources
► Compendium of significant
accounting and reporting
issues, 2016 AICPA National
Conference on Current SEC and
PCAOB Developments
(SCORE No. 04331-161US)

6. EY AccountingLink | ey.com/us/accountinglink
6 | SEC in Focus Issue 2, 6 April 2017
Mr. Bricker expressed concerns about the capacity of audit committees to balance their
workload, saying: “While audit committees may be equipped to play a role in overseeing risks
that extend beyond financial reporting, such as cybersecurity and portions of enterprise risk
management, I believe it is important for audit committees to not lose focus on their core
roles and responsibilities.”
To increase the effectiveness of their oversight, Mr. Bricker said audit committees should:
• Understand changes in the business, the operating environment and accounting
standards that may create different financial reporting risks
• Include members with diverse backgrounds and skills to effectively oversee financial
reporting and consider training and education programs to keep members current on
accounting and financial reporting developments
• Set a positive tone at the top to support a strong internal control environment
• Understand management’s disclosure controls and procedures over the accuracy of
non-GAAP and key operational measures and related policies, including how such policies
are administered
• Monitor any cost reduction initiatives that could adversely affect management’s ability
to meet its financial reporting responsibilities or inappropriately limit the scope of its
external audit
• Consider providing additional voluntary disclosures about how the audit committee
performs its oversight responsibilities, particularly its oversight of the external auditor
and financial reporting process
Current practice matters
Recent trends in SEC staff comments
Non-GAAP financial measures moved into the number 1 spot in our compilation of SEC staff
comment letters issued in the six months ended 31 December 2016, but the top five most
frequent areas for staff comments remained the same as in the 12 months ended
30 June 2016.
Ranking
Comment area 6 months ended 31
December 2016
12 months ended
30 June 2016
Non-GAAP financial measures 1 2
Management’s discussion and analysis 2 1
Fair value measurements 3 3
Segment reporting 4 5
Revenue recognition 5 4
We expect the SEC staff to continue to focus on these topics in 2017.
SEC staff focus on SAB Topic 11.M disclosures during filing reviews
The SEC staff has also indicated that it is closely monitoring company disclosures required
under Staff Accounting Bulletin (SAB) Topic 11.M about the effects the new accounting
standards on revenue recognition, leases and financial instruments will have on financial
statements when they are adopted. Below is an example of a comment letter that the SEC
staff recently sent a registrant about its SAB Topic 11.M disclosures on the new revenue
recognition standard.
EY resources
► SEC comments and trends – An
analysis of current reporting
issues, September 2016
(SCORE No. 03100-161US)
► Technical Line, 2016 trends in
SEC comment letters
(SCORE No. 03099-161US)

7. EY AccountingLink | ey.com/us/accountinglink
7 | SEC in Focus Issue 2, 6 April 2017
Example SEC staff comment: Accounting transition disclosures under SAB Topic 11.M
You state that you are in the process of evaluating the impact that the amended revenue
recognition guidance in Topic 606 will have on your consolidated financial statements.
Please revise to provide a qualitative discussion of the potential impact that this standard
will have on your financial statements when adopted. In this regard, include a description of
the effects of the standard’s provisions that you expect to apply and a comparison to your
current revenue recognition policies. Describe the status of your process to implement the
new standard and the significant implementation matters yet to be addressed. In addition,
to the extent that you determine the quantitative impact that adoption of Topic 606 will
have on your results, please also disclose such amounts. Please refer to ASC 250-10-S99-6
and SAB Topic 11.M.
While providing his views on SAB Topic 11.M disclosures included in recent SEC filings, Mr.
Bricker said at the 2017 Annual Life Sciences Accounting & Reporting Congress that some
companies have disclosed they don’t expect the effects of the new revenue standard to be
material. Mr. Bricker cautioned companies that even if they determine that the quantitative
effect on their financial results will not be material, they need to consider whether the new
disclosures they will have to make under ASC 606 are material. “The basis of any statement
that the impact of the new standard is immaterial should reflect consideration of the full
scope of the new standard, which covers recognition, measurement, presentation, and
disclosure for revenue transactions,” Mr. Bricker said.
2017 shareholder proposal landscape
Proxy access is once again the number 1 topic for shareholder proposals, according to a review
of nearly 650 proposals by our EY Center for Board Matters. Proxy access refers to the right to
include shareholder-nominated board candidates on a company’s ballot. The investor campaign
for proxy access has led a majority of S&P 500 companies to adopt proxy access bylaws over
the past three years. Nearly 20% of shareholder proposals this year focus on environmental
sustainability, with climate risk emerging as one of the top topics. Other hot topics include
political and lobbying spending, gender pay equality and board and workforce diversity.
2017 XBRL US GAAP taxonomy available for use
The SEC staff has updated the EDGAR system to allow companies to use the 2017 XBRL
US GAAP taxonomy, which adds tags for Accounting Standards Updates and makes certain
industry-related changes and other revisions. The SEC staff strongly encourages companies
to transition to the 2017 taxonomy for their first reporting period ending after 6 March 2017
(i.e., the first quarter Form 10-Q for calendar-year registrants). Companies also may continue
to use the 2016 or 2015 taxonomies. The staff does not expect to remove the 2015
taxonomy before June 2017.
Securities markets
NYSE changes listing standards for SPACs
The SEC approved rule changes by the New York Stock Exchange (NYSE or Exchange) that will
allow a special-purpose acquisition company (SPAC) listed on the Exchange to make a tender
offer to its shareholders in lieu of holding a shareholder vote on a proposed acquisition. That
tender offer must provide information about a proposed acquisition and an option for SPAC
shareholders who disagree with the proposed acquisition to exercise their redemption rights to
receive cash for their stock. The rule changes also eliminate a requirement that prevented a
SPAC from completing a business acquisition if a specified percentage of its shareholders (not
to exceed 40%) reject the proposed business acquisition and instead redeem their stock for
cash. The NYSE changes also lower the initial and continued market capitalization thresholds
required for SPAC listings.

8. EY AccountingLink | ey.com/us/accountinglink
8 | SEC in Focus Issue 2, 6 April 2017
Personnel changes
Sagar Teotia is new OCA Deputy Chief Accountant
The SEC named Sagar Teotia as the Deputy Chief Accountant overseeing the Accounting
Group in OCA. Before joining the SEC, Mr. Teotia was a partner at Deloitte & Touche LLP in its
National Office Accounting Consultations Group. He previously served as a professional
accounting fellow in OCA.
Other changes
Jennifer Minke-Girard has assumed the role of Interim Deputy Chief Accountant overseeing the
International Group in OCA. Her predecessor, Julie Erhardt, continues to serve as a deputy
chief accountant in OCA, focusing on emerging trends and accounting and auditing developments.
Enforcement activities
Non-GAAP disclosure rules
A marketing company settled charges with the SEC that it had violated non-GAAP disclosure
rules, as well as that it failed to disclose certain perquisites and benefits paid to its chief
executive officer (CEO).
The company didn’t admit or deny the SEC’s findings that it failed to give US GAAP metrics
prominence equal to or greater than non-GAAP measures in its earnings releases and that it
had changed the way it calculated its non-GAAP measure of “organic revenue growth” in
2012 without informing investors. According to the SEC, the company said organic revenue
growth excluded the effects of two items (“acquisitions and foreign exchange impacts”), but it
actually excluded a third item (i.e., the impact of gross vs. net revenue adjustments) beginning
in 2012, which was not disclosed. The company’s organic revenue growth would have been
lower if the company had calculated the measure consistently, the SEC concluded.
The SEC also found that the company did not disclose perquisites provided to its CEO that
included private aircraft usage, club memberships, cosmetic surgery, yacht and sports car
expenses, jewelry, charitable donations, pet care and personal travel expenses. The CEO later
resigned and agreed to repay to the company more than $21.8 million in cash bonuses and
personal benefits received between 2009 and 2014.
The company agreed to take remedial actions and pay penalties of $1.5 million to settle
the charges.
Fictitious revenues
A Mexico-based homebuilder agreed to settle charges that it recorded fictitious sales of over
100,000 units and overstated its revenues by $3.3 billion from 2010 to 2012. In 2013, the
company began defaulting on its debt obligations, and it filed for the Mexican equivalent of
bankruptcy reorganization in 2014. The company emerged from bankruptcy in 2015. In
settling the case, the SEC said it took into account that the fraud occurred under previous
management and ownership, and the new owner has taken appropriate remedial actions and
significantly cooperated with the SEC during the investigation. No monetary penalties were
imposed as part of the settlement.
Understating income tax expense and liability
The SEC charged a shipping conglomerate and its former chief financial officer (CFO) with
failing to recognize approximately $512 million of income tax liabilities over nearly 12 years.
Certain terms in the company’s credit agreement made its controlled foreign subsidiary
“jointly and severally” liable for the company’s debt, meaning the company should have

9. EY AccountingLink | ey.com/us/accountinglink
9 | SEC in Focus Issue 2, 6 April 2017
considered the guaranteed amount taxable income because it was a “deemed dividend” under
the US tax code. The CFO did not consider these facts in determining the company’s income
tax provision. The company filed for bankruptcy court protection after it discovered the
understatement. The company agreed to pay a $5 million penalty, subject to bankruptcy
court approval, and the former CFO agreed to pay a $75,000 penalty.
Fictitious expense reimbursements and claims for incentive compensation
The SEC charged two former senior executives of a credit card processing company and three
others with falsifying expense reimbursements, receiving kickbacks on overpayments to third
parties and inappropriately claiming commissions or bonuses on existing customer accounts.
The executives allegedly colluded, overrode internal controls and lied to the outside auditor.
The alleged fraud was uncovered in August 2012 based on an employee tip and totaled
$11.6 million since it began in 2008. A company investigation resulted in the termination of
the senior executives. The company also restated its financial statements for the affected periods.
The SEC is seeking penalties, disgorgement and other prohibitions against the defendants.
Impeding whistleblowers
The SEC settled charges against an asset management company and a financial services
company for impeding their former employees’ communications with the SEC staff about
possible securities law violations.
The SEC found that the asset management company violated the whistleblower protections
available under the Dodd-Frank Act by requiring departing employees to waive recovery of
incentives for reporting misconduct available under the rule, among other things, in exchange
for separation payments. The company voluntarily revised its separation agreements last
year to prevent any such future violation.
In connection with an SEC investigation of a financial services company’s hedge accounting,
the SEC found that the company similarly violated the whistleblower protections through
language in its severance agreements. As part of remedial actions, the company also changed
its severance agreements last year.
What’s next at the SEC?
Mr. Clayton’s confirmation as SEC Chairman would allow him to provide direction to the
Commission and its staff and fill key staff positions. However, even if Mr. Clayton is
confirmed, one of the other two commissioners still could block a rule by not participating,
potentially limiting how active the Commission can be on rulemaking activities until either
of the other two remaining vacancies is filled.
EY| Assurance| Tax | Transactions | Advisory
© 2017 Ernst & Young LLP.
All Rights Reserved.
SCORE No. 01607-171US
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