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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 (Fifth Edition)
    This new release in Deloitte’s SEC Comment Letter series includes extracts of frequently issued SEC staff comments, additional analysis, and links to related resources that are relevant to SEC filers. The fifth edition features:
    • New and updated areas of focus related to financial statement accounting and disclosures, including loss contingencies, income taxes, valuation of assets, revenue recognition, and segments.
    • New and updated topics in other disclosure areas, including MD&A, risk factors, proxy disclosures, and non-GAAP financial measures.
    • Expanded discussions of industries covered in the fourth edition, including retail, energy and resources, financial services, health sciences, technology, and telecommunications.
    • Added discussion of trends affecting aviation and transport registrants.
    • New coverage of comment trends related to initial public offerings.
    • 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 (Second Edition)
    This revised edition of SEC Comment Letters on Foreign Private Issuers Using IFRSs — A Closer Look reflects new topics and updates existing topics to reflect new areas that the SEC staff has commented on since the release of the first edition in January 2008. The SEC staff has continued to issue comments on topics included in the first edition of this publication, such as financial instruments, financial statement presentation, revenue recognition, provisions, and income taxes. This second edition not only provides revised coverage of these topics but also adds four new topics: share-based payment, business combinations, earnings per share, and intangible assets. In addition to an overall analysis of the nature and types of SEC staff comments, this publication includes extracts from actual comment letters, accompanied by a discussion of the topic involved as well as forward-looking considerations.

    This publication will be particularly useful both for companies that are currently using IFRSs and those that are looking to learn more about IFRSs. Understanding the SEC staff’s comments has become increasingly important given the use of IFRSs around the world and the increased likelihood that the SEC will eventually require the use of IFRSs for U.S. registrants.

 

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