The EXIT Alliance this week submitted a formal comment letter to the SEC on its proposal to modernize emerging growth company accommodations and simplify filer status for reporting companies. The coalition's letter supports the Commission's broader effort to rightsize an increasingly complex reporting regime, while urging a more careful, evidence-based approach to the proposal's most consequential piece: expanded relief from Sarbanes-Oxley Section 404(b) auditor attestation requirements.

The letter lays out four guiding principles for disclosure modernization — reduce friction while preserving confidence, scale requirements to their informational value, measure success by long-term market quality (not just lower compliance costs), and treat modernization as iterative rather than a one-time fix. Applying that framework, EXIT Alliance backs several of the SEC's proposed simplifications as sound regulatory housekeeping — including updated filer classifications and the removal of duplicative Regulation S-X disclosures — but recommends the Commission ground any expansion of the 404(b) exemption in empirical data on restatement rates and control deficiencies before finalizing the rule at the proposed $2 billion threshold.

The coalition also calls for the SEC to build periodic reassessment into the final rule, noting the current $700 million large accelerated filer threshold went unchanged for two decades before this proposal.