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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: Constructing Clear Disclosures (Seventh 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 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.


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.


SEC Comment Letter Examples — Income Taxes (January 2014 Edition)
Accounting for income taxes continues to be one of the SEC’s top areas of focus in its reviews of registrant’s periodic filings. This edition of SEC Comment Letter Examples — Income Taxes contains extracts of SEC staff comments on topics including a registrant´s assessment of the realizability of deferred tax assets, undistributed earnings of foreign subsidiaries, foreign impact on the effective tax rate, uncertain tax positions, and income tax accounting disclosures. The extracts have been reproduced from comments published on the SEC´s Web site that were issued between January 1, 2012, and June 30, 2013.

As used on this page, "Deloitte" means Deloitte & Touche LLP, a subsidiary of Deloitte LLP, Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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