deloitte sec comment letter trends

b. I would add that we've seen comment letters come in the last week, and I'm sure we'll see comment letters come in in the weeks and months to come. The focus of the SEC staff’s comments on Internal Control over Financial Reporting (ICFR) has not changed significantly from prior years. As you know, a Johnson & Johnson shareholder submitted … The more easily identifiable issues, such as undue prominence and net of tax presentation, are still addressed but the percentage of companies receiving … During 2014, however, regional cycles are back, as political, social, and economic instability has led to automotive sector losses within three of the four BRIC markets while the U.S. and EU remain on the path to recovery. Following the best practices in Appendix B often leads to a relatively short dialogue with the SEC staff. 3 Stay informed| SEC comment letter trends | Automotive Overview Last year, the global automotive industry experienced an unusual period of uniform geographic growth. 18:46 - Non-GAAP. 1. a. Focus areas have included: the presentation with equal or greater prominence of the … It's not like the SEC has a deadline per se where they say ‘All comments have to be issued on such and such date.’ They're going to continue to pull in. The SEC’s EDGAR database provides free public access to company filings, including the Commission’s comment letters and responses from registrants. Recent SEC Comment Letter Looks Under the Hood at SPAC Merger Diligence. Status of development efforts for new or enhanced products, trends in market demand, and competitive conditions . LinkedIn Facebook … 31:02 - Best practices. The Division’s recent comment letters have particularly focused on the use of non-GAAP measures in press releases. Other Publications, Press Releases, and Reports. a. A Roadmap to SEC Comment Letter Considerations, Including Industry Insights Chapter 1 — Before the Details: Trends and Priorities 1.5 Comment Letters per Review and Days to Complete a Review Ryan shares his observations with respect to the overall trends in SEC comment letters in 2020, including: 13:16 - MD&A. Their research shows an inverse relationship in the overall number of comment letters issued and the percent of letters referencing non-GAAP issues. Jay Knight. Deloitte Omnia produces insights that are tailored for your business and the industry it operates in. Posted on July 13, 2018 by Joey Bonaldi. Gensler’s predecessor, Jay Clayton, oversaw the … Our SEC Reporting Update publication focuses on key trends in SEC staff comment letters issued for the year ended 30 June 2019, including an increase in comments related to the new revenue standard and a focus on the use of non-GAAP measures that employ individually tailored accounting principles. 27:29 - Segment reporting. 17:07 - COVID-19. PCAOB. In many instances, the Division has asked companies to make sure that non-GAAP measures are not more prominent than GAAP measures. The total amount of comment letters stemming from 10-K and 10-Q filings has once again decreased (as shown in the chart below). They continue to focus on: the identification and disclosure of material weaknesses. View image Non-GAAP financial measures result in frequent comments regarding compliance with Item 10(e) of Regulation S-K and the related compliance and disclosure interpretations, sometimes resulting in requests to remove or substantially modify non-GAAP metrics. Overall, these trends suggest that more complex and significant issues with non-GAAP financial reporting measures, such as tailored accounting and free cash flows, are being addressed more often in SEC comment letters to registrants. We identify what matters through our advanced analysis which looks for hidden patterns, trends, and risks in your large data sets and journal entry populations. v SEC Comment Letters — Including Industry Insights Executive Summary Executive Summary In 2013, the SEC underwent many leadership changes with the appointment of three new commissioners (including a second new chairman, Mary Jo White, to replace Elisse Walter), two co-directors of the SEC’s Division of Enforcement, and a new director of the SEC’s Division of Corporation Finance. SEC comment letter series; TRG Snapshot; Accounting Spotlight; On the Radar; Non-English publications ; Third party publications; IFRS e-learning; Info. See Deloitte’s SEC Comment Letters — Including Industry Insights: What “Edgar” Told Us for a more detailed discussion of trends identified in the SEC staff’s comment letters on non-GAAP measures. We have commented on IASB post-implementation review IFRS 10 ‘Consolidated Financial Statements’, IFRS 11 ‘Joint Arrangements’, IFRS 12 … During that time, SEC staff … Comment Letter Trends and Statistics section below, we, in turn, continue our tradition of highlighting trends in SEC staff comments by analyzing comments issued by the staff over the past year. Much of the decline was due to a government shutdown that persisted through the first 25 days of 2019. Posted on June 18, 2019 by Olga Usvyatsky. SEC Rules & Regulations ... XBRL-Formatted Information New Technical Questions and Answers Audit and Accounting Guides & Audit Risk Alerts Accounting Trends and Techniques Practice Aids New SASs, SSAEs, and SSARSs AICPA Issues Papers. Final Amendments . Deloitte recently posted an excellent study regarding SEC comment letter trends.. The Deloitte study highlights the significant increase in 2016 in SEC comments regarding non-GAAP financial measures, which is no surprise in light of the SEC’s public comments regarding this issue and the new SEC guidance (C&DIs) released in May 2016, and is consistent with trends we have been seeing. 25:37 - Revenue recognition. A Recap of Recent Trends Eighth Edition November 20, 2014. ii SEC Comment Letters — Including Industry Insights To our clients, colleagues, and other friends: We are frequently asked to provide our perspective on the topics the SEC staff focuses on in its comment letters to registrants. PCAOB Standards and Related Rules PCAOB Material — Supplement. Between 2018 and 2019, the number of comment letters fell by roughly 30%; similarly, between 2017 and 2018, there was a 32% decline. On February 27, 2018, the World Business Council for Sustainable Development (WBCSD) and the Climate Disclosure Standards Board (CDSB) released a new report that maps global and regional environmental, social and governance (ESG) reporting trends. Deloitte comment letter on the IASB's post-implementation review of IFRS 10, IFRS 11, and IFRS 12. published 10 May 2021. SEC Comment Letters: An Eight Year Trend. us SEC Comment Letter Trends Explore industry-specific SEC comment letter trends by selecting an industry below or return to the overall comment letter trends : Consumer markets SEC Comment Letters: A Seven Year Trend. Roadmap series Roadmaps provide in-depth summaries of complex areas of accounting and financial reporting. The SEC in recent days sent letters to Wall Street banks seeking information on their special purpose acquisition company, or SPAC, dealings, Reuters reports. 11. From 2017 to 2018, total comment letters decreased by roughly 26%, which is slightly steeper than the decline we’ve seen in the past (13% from 2016 to 2017 and 10% from 2015 to … By understanding trends in SEC comment letters, CFOs and Finance Teams can proactively identify and address potential gaps in their financials. Resources material to a registrant’s business . Comments on the Proposed Amendments (iii). As with every year we will look primarily at comments from 10-K’s and 10-Q’s, but like last year we will also be analyzing 8-K’s and what insights we can garner from them. The panel includes former members of the SEC staff members who will share experiences, observations and lessons from the SEC comment letter process as well as insights from EY’s latest SEC Comments and Trends publication. us SEC Comment Letter Trends . b. On October 16, 2018, Audit Analytics published an article looking at the trends of comment letters issued referencing form types 10-K, 10-K/A 10-Q, 10-Q/A and 8-K filings from January 2010 through June 2018. Before wrapping up, Ryan and Kyle provide a handful of best practices on the most effective way to respond to comment letters. Bass, Berry & Sims PLC + Follow Contact. It is time once again to look at macro trends in SEC Comment Letters. The SEC did not immediately have comment on the letter. Our analysis of SEC comment letter trends for the financial services industry identifies the frequency of topical areas addressed by the SEC staff and how their focus areas changed over time, as well as provides sample text from the comments. us SEC Comment Letter Trends . Archive. Be sure to check out Deloitte’s A Roadmap to SEC Comment Letter Considerations, Including Industry Insights, EY’s SEC Comments and Trends – September 2018, and PwC’s SEC Comment Letter Trends for further analysis of SEC comment letters. If you receive a comment letter from the SEC staff, view it as an opportunity to educate the staff about your facts and how you arrived at the conclusions leading to your disclosure, which may include your consideration of materiality. For more information on the top issues in comment letters, please contact us at info@auditanalytics.com or call (508) 476-7007. The PCAOB has been beset by scandal in recent years. Raw materials (ii). 3. To start with a very recent example, I have concerns about CII’s position with respect to the Johnson & Johnson shareholder proposal. Other. A review of SEC comment letters on forms 10-K, 10-Q, and 8-K shows that the trend of comment letters has continued to decline. Proposed Amendments and Comments . 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