SEC Comment Letters — Including Industry Insights: Highlighting Risks
Sixth Edition (November 2012)
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.
View all issues in the series.
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