The CHRO Association submits these comments in response to the rule proposal issued by the Securities and Exchange Commission (SEC) regarding the simplification of filer status for public companies (“Proposal”). We appreciate the SEC’s ongoing efforts to reform public company reporting requirements and are pleased to provide our views on the Proposal.

The CHRO Association is a public policy advocacy organization that represents the most senior human resource officers (CHROs) in nearly 400 of the largest corporations across industries doing business in the United States and globally. Collectively, these companies employ more than 10 million employees in the United States, nearly nine percent of the private sector workforce, and 20 million employees worldwide. Approximately two-thirds of the Association’s members are federal contractors, including those operating within the defense industry.

Under current SEC rules, based upon metrics such as public float and annual revenue, issuers may qualify as a 1) Large accelerated filer (LAF); 2) Accelerated filer (AF); 3) Non-accelerated filer (NAF); 4) Smaller reporting company (SRC); or 5) Emerging growth company (EGC). Each status confers a specific regulatory framework upon issuers. Many companies qualify as more than one type of filer; for example, the Proposal notes that in 2024 NAFs that were also SRCs or EGCs (or both) accounted for 51.9% of all issuers.[1]

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