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SEC Comment Letters — Including Industry Insights: Improving Transparency

Fifth Edition (November 2011)


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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.

View all issues in the series.

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