Comment letter to the U.S. Securities and Exchange Commission ("SEC") with suggestions related to its Disclosure Effectiveness review. The Society's letter strongly supports the efforts of the Division of Corporation Finance to improve disclosure efficiency and effectiveness. The letter makes concrete suggestions to improve disclosure by eliminating obsolete information which is readily available elsewhere as a result of changes in technology, eliminating duplicative or redundant disclosure, and by taking a principles based approach that would require a basic set of information but also allow companies flexibility to exercise judgment in applying disclosure requirements to communicate about their own businesses and circumstances.