On June 27, 2020, the Board of Directors of the Company approved a restructuring plan that incorporates actions related to the recent ownership restructure of Dow Corning Corporation ("Dow Corning"). These actions, aligned with Dow’s value growth and synergy targets, will result in a global workforce reduction of approximately 2,500 positions, with most of these positions resulting from synergies related to the Dow Corning transaction. These actions are expected to be substantially completed by June 30, 2022. As a result of these actions, the Company recorded pretax restructuring charges of $449 million in the second quarter of 2020 consisting of severance charges of $268 million, asset write-downs and write-offs of $153 million and costs associated with exit and disposal activities of $28 million. The SEC has expressed concern about abuses surrounding restructuring charges. What is the nature of the SEC’s concerns?