Agenda Request Regarding Disaggregated Disclosure of Unrealized Gains from Commercially Entangled Equity Investments under ASC 321 | Financial Accounting Standards Board (FASB), June 2026
Submitted an agenda request urging the Board to amend ASC 321-10-50 to require disaggregated disclosure of remeasurement gains on equity holdings where the investee is also a material commercial counterparty of the reporting entity, drawing on original research into the financial architecture of cloud provider–AI developer partnerships.
Proposed accompanying note and narrative disclosures quantifying entanglement-driven gains and the associated cloud credit arrangements, framed as a disclosure-only change consistent with the Board's income statement disaggregation work under ASU 2024-03.
Petition for Rulemaking Regarding Disaggregated Disclosure of Cloud Revenue and Unrealized Gains from Commercially Entangled Entities in the AI Infrastructure Sector | U.S. Securities and Exchange Commission (SEC), June 2026
Petitioned the Commission to amend Regulation S-K to require disaggregated disclosure of cloud computing revenue from commercially entangled entities, and proposed interpretive guidance requiring separate below-the-line presentation of mark-to-market gains where the investee is also a material commercial counterparty.
Recommended that the Commission refer to the Financial Stability Oversight Council whether the interaction among cloud credit investments, mark-to-market accounting, and passive index fund flows constitutes an emerging systemic risk to household retirement savings.
Public Comment Regarding Draft Guidelines on Transparency Obligations under Article 50 AI Act | European Commission, AI Office, May 2026
Provided stakeholder input on the regulatory treatment of algorithmic recommender systems under the AI Act's transparency framework, arguing that the current scope exclusion for recommender systems creates compliance uncertainty for stakeholders subject to both the AI Act and DSA, and proposing that transparency obligations encompass disclosure of AI systems' optimization objectives.
Public Comment Regarding Making Improvements to the Premerger Notification and Report Form | U.S. Department of Justice (DOJ) & Federal Trade Commission (FTC), May 2026
Provided expert analysis on how acqui-hire transactions and cloud credit investments in the AI sector evade HSR premerger reporting requirements, drawing on original research into the financial architecture of cloud provider–AI developer partnerships. FTC-2026-0298-0004
Recommended targeted modifications to the HSR form, including bright-line filing thresholds for structured talent acquisitions and disclosure requirements for in-kind infrastructure investments, with attention to proportionality and administrative burden.
Public Comment on Competitor Collaboration Guidance |U.S. Department of Justice (DOJ) & Federal Trade Commission (FTC), April 2026
Provided expert analysis on non-traditional transaction structures (cloud credit investments, reverse acqui-hires) for the Agencies' joint inquiry on Docket No. ATR-2026-0001.
Recommended updates to the Antitrust Guidelines to capture competitive effects of AI infrastructure financial architectures.
Read the full comment on Regulations.gov → https://www.regulations.gov/comment/ATR-2026-0001-0015