In a recent letter, the Chamber commented to the SEC’s Advisory Committee on Small and Emerging Companies about the Committee’s consideration of the factors affecting the trend of companies remaining private and deferring their IPOs.  The Chamber’s letter attributes some of the “hurdles” of becoming a public company to the SEC’s complex disclosure requirements, recent specialized disclosure requirements, and the influence of proxy advisory firms on governance in U.S. public companies.  The Chamber recently published a white paper, Essential Information:  Modernizing Our Corporate Disclosure System, which addresses materiality as a guiding principle for securities disclosures and cautions against “special interest disclosure” requirements.  Presumably, the SEC will continue to advance the disclosure effectiveness initiative, which had been undertaken under former Chair White’s leadership.

The Chamber’s letter is available here:  http://www.centerforcapitalmarkets.com/wp-content/uploads/2017/02/2017.2.15-US-Chamber-Letter-to-SEC-re-advisory-cmte-meeting-on-companies-staying-private.pdf?x48633

The Chamber’s white paper is available here:  http://www.centerforcapitalmarkets.com/wp-content/uploads/2013/08/U.S.-Chamber-Essential-Information_Materiality-Report-W_FINAL.pdf?x48633