Submission to the U.S. Securities and Exchange Commission

Comment on Regulation S-K Modernization

Regulator
U.S. Securities and Exchange Commission (SEC)
Date filed
Filed by
Auditchain Labs AG
File number
CLL-15

Summary

Responding to SEC Chairman Atkins' Statement on Reforming Regulation S-K, this letter argues that the materiality problem is as much about how disclosure is made as what is disclosed. It recommends extending Inline XBRL requirements from Regulation S-X financial statements to key S-K items — Item 101 (Business), Item 105 (Risk Factors), Item 106 (Cybersecurity), Item 303 (MD&A), and Item 601 (Exhibits); adopting BNP disclosure requirements for registrants materially dependent on public networks; and coordinating SEC taxonomy development with the FDIC and OCC frameworks for interagency consistency. It draws four blockchain disclosure categories from the FDIC questionnaire and taxonomy, anticipating the new classes of SEC-registered entities the GENIUS and pending CLARITY Acts will create.

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