In November and December 2018, SEC Chair Clayton, Chief Accountant Bricker and several other staff members discussed the use of S-X Rule 3-13 waivers. These waivers may be appropriate when a mechanical application of rules like the significant subsidiary test yield results that may require costly disclosures that might not be material to investors. All of the SEC speakers emphasized that such waivers require thorough analysis and are not automatic. The SEC staff has processes in place to respond to these requests in a timely manner.
As always, your thoughts and comments are welcome!