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SEC Comment Letters — Including Industry Insights: Constructing Clear Disclosures

Seventh Edition (December 5, 2013)


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 seventh edition features:

  • New and updated analysis of comments related to MD&A, risk factors, and financial statement accounting and disclosures, including:
    • Quantification and analysis of factors causing changes in registrants’ results of operations.
    • Liquidity risks and restrictions on a registrant’s ability to transfer cash or pay dividends.
    • Cybersecurity risks, disclosures pertaining to sponsors of state terrorism, and non-GAAP financial measures.
    • Disclosures related to unobservable inputs in Level 3 fair value measurements.
    • Revenue recognition disclosures, including those about multiple-element arrangements.
    • Segment reporting, particularly if operating segments are aggregated.
  • Added coverage of comment trends regarding emerging growth companies and initial public offerings.
  • Expanded discussions of industries covered in the sixth edition, including retail; travel, hospitality, and leisure; energy and resources; financial services; health sciences; technology; and telecommunications.
  • 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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