SEC Comment Letter Publications
Use the links below to access all of the issues of the SEC Comment Letter Publications series.
Subscribe to publications prepared by the Accounting Standards & Communications Group.
SEC Comment Letters — Including Industry Insights: Highlighting Risks (Sixth Edition)
This new release in Deloitte’s SEC Comment Letter series includes extracts of frequently issued SEC staff comments, additional analysis, and links to resources that are relevant to SEC filers. The sixth edition features:
- New and updated analysis of comments related to MD&A, risk factors, and financial statement accounting and disclosures, including:
- Risks associated with operating in foreign countries.
- Early-warning disclosures of circumstances that may give rise to material charges such as those related to loss contingencies, income taxes, and valuation of assets.
- Liquidity risks and restrictions on a registrant’s ability to transfer cash or pay dividends.
- Cybersecurity risks, proxy disclosures, and non-GAAP financial measures.
- Added coverage of comment trends regarding emerging growth companies.
- Expanded discussions of industries covered in the fifth edition, including retail, energy and resources, financial services, life sciences and health care, technology, and telecommunications.
- Added discussion of industry-specific trends affecting aerospace and defense and travel, hospitality, and leisure registrants.
- Appendixes offering insights into current standard setting, the SEC staff’s review and comment letter process, best practices for managing and resolving SEC comment letters, and helpful tips on searching the SEC’s comment letter database.
SEC Comment Letters on Foreign Private Issuers Using IFRSs (Third Edition)
This revised edition of SEC Comment Letters on Foreign Private Issuers Using IFRSs — A Closer Look provides insight into the topics upon which the SEC staff has focused in its reviews of foreign private issuers’ periodic filings. Such items include financial instruments, presentation of financial statements (including the statement of cash flows), revenue recognition and related costs, segment reporting, income taxes, provisions and contingent liabilities, business combinations, intangible assets, and disclosures in other sections of the periodic filings, including operating and financial review and prospects.
The third edition includes discussions of the following new areas of frequent SEC comment: first-time adoption of IFRSs; impairment of assets; consolidated financial statements, investments in associates, and interests in joint ventures; property, plant, and equipment; employee benefits; discontinued operations; and other disclosure topics, such as risk disclosures, non-GAAP financial measures, controls and procedures, and guarantor financial statements.
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