Read a December 2020 report [PDF 80 KB] prepared by KPMG LLP: What's News in Tax: SEC Comments on Accounting for Income Taxes. • Comment letter language includes "Topic 606", "ASC 606" or "ASU 2014-09". SEC Comment Letter Considerations, Including Industry Insights dart.deloitte.com Like Comment. For cost of sales, the SEC staff focused on the components of cost of sales, ensuring non-cash items, like depreciation, were allocated to cost of sales, and questioning the calculation of gross margin when it was not. The seventh edition of SEC Comment Letters — Including Industry Insights: Constructing Clear Disclosures offers such perspective. ASC 606, ASC 340-40, and all recently issued ASUs for these topics. SEC Comment Letter Publication. 25:37 - Revenue recognition. Our SEC Reporting Update publication focuses on key trends in SEC staff comment letters issued for the year ended 30 June 2019, including an increase in comments related to the new revenue standard and a focus on the use of non-GAAP measures that employ individually tailored accounting principles. 17:07 - COVID-19. October 26, 2021 @ 1:00 pm - 2:00 pm EDT. Publication date: 12 Mar 2021. us SEC Comment Letter Trends. Matt Burley. Deloitte Touche Tohmatsu's IAS Plus Web site), and Appendix E contains a glossary of standards used throughout this publication. The… Notably, Deloitte's "SEC Comment Letters - Including Industry Insights: What "Edgar" Told Us", issued in October 2015, covers the whole spectrum; and EY offers a number of industry-specific publications that shed light on the issue. . See Deloitte's April 2, 2012, Heads Up for additional information. The downside is not being able to lift my toddler, but with a 10 year old you shouldn't have the issue! Non-GAAP financial measures result in frequent comments regarding compliance with Item 10 (e) of Regulation S-K and the related compliance and disclosure interpretations, sometimes resulting in requests to remove or substantially modify non-GAAP metrics. comment letter. The process for providing comment letters for registration statements depends on whether the registration statement is filed publicly or submitted confidentially: • For registration statements that are publicly filed, the SEC staff will call either the registrant or legal counsel to obtain the appropriate e-mail address. As of January 31, 2020, the SEC had issued 160 comment letters concerning revenue recognition disclosure requirements (ASC 606-10-50). And in February 2009, Deloitte published a revised edition of the first report: SEC Comment Letters on Domestic Registrants: A Closer Look (PDF 810k). The SEC staff comments relating to accounting changes and errors asked registrants to provide: additional information regarding management's evaluation of materiality in accordance with SAB Topics 1.M and 1.N; and 10:30 - 11:45 IPOs and SPACs Update. Companies Resist SEC Climate-Disclosure Requests as Rules Stall. Waiting for Deloitte offer letter. • SEC Comment Letters on Foreign Private Issuers Using IFRSs — A Closer Look, Third Edition (March 2012). Overview. Business Acquisitions — SEC Reporting Considerations Business Combinations Carve-Out Transactions Comparing IFRS Standards and U.S. GAAP Consolidation — Identifying a Controlling Financial Interest Contingencies, . While the population isn't significant, a few helpful hints can be gleaned from publicly available SEC comment letters on the 2017 filings of some of these early adopters. Is based on SEC uploads (i.e., comment letters that the SEC issued to registrants) and does not include registrant responses. Meghan Depp, BDO, National SEC Office Carly Ackerman, Deloitte Consulting, Manager Was waiting for my offer letter from 3 weeks and got a email from HR saying they were waiting from to get approval from a principal director he has resigned and so they are looking for replacement and keep the process on hold for all candidates. DART pending content manager is OFF. Comment letter topics. PwC responds to SEC proposal to modernize and simplify Regulation S-K. December 21, 2017. All companies; Disclosure, disclosure, disclosure. Some responders believe that continued emphasis on convergence is the best course of action, while others have requested that the Deloitte A Roadmap to SEC Comment Letter Considerations, Including Industry Insights (2019) 2.4 Debt 20 2.4.1 Restrictions 20 2.4.2 Financial Covenant Disclosures 22 2.4.3 Classification as Debt or Equity 22 2.5 Discontinued Operations, Assets Held for Sale, and Restructuring Charges 23 The primary reason for tax-related SEC comment letters is a lack of disclosure and clarity in the income tax footnote related to items such as undistributed foreign earnings, uncertain tax positions and valuation allowances (Deloitte 2012; PWC 2013). The SEC staff comments for inventory focused on disclosing the basis of accounting for inventory. Fields. 10:15 - 10:30 Break. Please note that we now accept comment letters in PDF format. Previous Section Next Section. Viewing offline content Limited functionality available Dismiss Services What's New The Ripple Effect Learn more about the power of Intelligize! Moreover, an SEC comment letter can be viewed as the vi SEC Comment Letters — Including Industry Insights Executive Summary Executive Summary In October 2014, a new chief accountant, James Schnurr, assumed leadership of the SEC's Office of the . 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. Our analysis of SEC comment letters issued in relation to Form 10-K and Form 10-Q filings identifies the frequency of topical areas addressed by the SEC staff and how their focus areas changed over time. On September 22, 2021, the DCF publicly released a sample letter that highlights the types of comments the DCF may issue to public companies regarding climate-related disclosures, primarily focusing on disclosures in the business, risk factors, and MD&A sections of filings. SEC reporting reminders. The planned C was a walk in the park in comparison. Deloitte issued a publication in November 2017, SEC Comment Letters - Including Industry Insights that provides insight on the top 10 comment letter topics and is a great resource for accountants as we focus on the annual calendar year-end reporting fun! 2:20 SEC Comment Letter Update and Legal Issues. Submitted Comments (Click here for meetings with SEC officials) Comments have been received from individuals and entities using the following Letter Type A: 19 B: 2,281 C: 2,070 D: 1,506 : Feb. 10, 2022 For additional discussion into the comment letter process see Deloitte's SEC Comment Letters — Including Industry Insights which highlights some of the topics above including comments related to predecessor financial statements, dilution disclosure pursuant to Item 506, and age of financial statements. Comment letter topics 10:15 - 10:30 Break. This month, Deloitte & Touche LLP released its annual study on the Securities and Exchange's ("SEC") recent comment letters. . Deloitte (United States) has published the fourth edition of its SEC comment letter publication SEC Comment Letters — Including Industry Insights: A Snapshot of Current Themes. Forms 20-F, as well as comments relating to IPOs and other securities offerings. In addition to extracts of letters and links to relevant related resources, it contains analysis . Deloitte & Touche LLP +1 415 783 6613. johnwilde@deloitte.com. Deloitte recently posted an excellent study regarding SEC comment letter trends.. The 2017 edition of SEC Comment Letters — Including Industry Insights offers such perspective. Other features include (1) an update on the SEC's priorities; (2) a summary of comment letter trends related to the top 10 topics of frequent comment in the 12-month period ended July 31, 2019; and (3) topics of focus related to . Footnotes. Additional Deloitte Guidance. In their SEC Comment Letter Series, Deloitte (2015) makes note of comments made by SEC staff at public speaking engagements, as well as samples from comment letters to registrants. Other features include (1) an update on the SEC's priorities; (2) a summary of comment letter trends related to the top 10 topics of frequent comment in the 12-month period ended July 31, 2021; and (3) topics of focus related to . Please note that SEC only publishes comment letters that have been fully addressed and closed. This publication contains extracts of frequently issued SEC staff comments, analysis of those extracts, and links to resources that are relevant to SEC filers. SEC Commentary on ASC 606 Revenue Recognition Disclosures. #deloitte #10K #10Q #secreporting #commentletters https://lnkd.in/gJtr3NYp. Goodwill and other intangibles. Deloitte Comment Letters. That said, the SEC also raised several additional points: Current expected credit loss (CECL). The following illustrative letter contains sample comments that the Division may issue to companies regarding their climate-related disclosure or the . Non-GAAP measures. Please enable JavaScript to view the site. Appendix B: Best Practices for Managing Unresolved SEC Comment Letters 104 Appendix C: Tips for Searching the SEC's Database for Comment Letters 105 Appendix D: Deloitte Resources 110 Appendix E: Glossary of Standards 112 s 144 Appendix C: Tips for Searching the SEC's Database for Comment Letter. SEC comment letters on revenue recognition implementation and disclosures are still a top-ten issue at the SEC, and by the end of 2019 may surpass the number of comment letters issued on non-GAAP measures—which has been the top SEC comment letter subject for the past few years. Insiders are another stakeholder group who are well-placed to be aware of important . In January, I passed along a list of 12 review and comment priorities distributed at the 48th Annual Institute on Securities Regulation in New York by a panel of speakers that included. PwC supports the SEC's proposal to simplify and modernize the disclosure requirements of Regulation S-K, which will impact most US registrants. Appendix B: Best Practices for Managing Unresolved SEC Comment Letter. Participants of the live webinar will be eligible for 1 free CPE credit. 8:45 - 10:15 SEC Update. Deloitte & Touche LLP 2014). In this webcast, KPMG professionals discuss recent themes and trends in comment letter activity from the SEC and what areas of focus may be on the horizon. Feb. 14, 2022, 1:56 PM. 153 Appendix F: Abbreviation. DART pending content manager is OFF. Deloitte comments on key proposals from the FASB, SEC, and related organizations. Intelligize is a SEC filing analytics & compliance platform that enables you to gather & analyze related securities documents such as SEC filings, 10-K, EDGAR, associated exhibits, comment letters and responses, deal summaries and underlying agreements, & much more. Mr. Brent J. Deloitte comment letter on SEC's requests for input on climate-related and other ESG disclosures Deloitte comment letter on SEC's requests for input on climate-related and other ESG disclosures Published on: 22 Jun 2021 • Assist client service personnel and clients in responding to SEC comment letters and preparing pre-filing letters • Assist in developing Deloitte positions on SEC reporting issues and . Textual Classification of SEC Comment Letters James P. Ryans Haas School of Business, University of California at Berkeley, Berkeley CA 94720 Abstract I utilize Naive Bayesian text classification to signal important SEC comment letters, where negative abnormal returns following comment letter disclosure is the measure of importance. In 2017, 1,491 comment letters were issued by the SEC, a 13% decline from 2016 and a 54% decline over the . Those comment letters viii SEC Comment Letters — Including Industry Insights The table below summarizes comment letter trends in the 12-month periods ended July 31, 2015, and July 31, 2014:8 12 Months Ended July 31, 2015 12 Months Ended July 31, 2014 Topic Number of 10-K and 10-Q Reviews With Comment Letters That Include a Comment on Topic Percentage of All Comment 2007 comment letter to the PCAOB, and contrary to the Board's statement in Partner. Deloitte's US GAAP Plus Web site is a resource you can use to keep current on the SEC's latest . This month, Deloitte & Touche LLP released its annual study on the Securities and Exchange's ("SEC") recent comment letters. Required subscriptions US GAAP View all / combine content However, these reviews also impose significant costs on companies because comment letter remediation diverts time and resources away from normal operations and may result in restated or amended filings . 18:46 - Non-GAAP. Read more You must log in to view this content and have a subscription package that includes this content. COVID impact. Ryan shares his observations with respect to the overall trends in SEC comment letters in 2020, including: 13:16 - MD&A. The SEC periodically reviews public-company nancial statements, issuing comment letters in response . December 21, 2017. Our SEC Reporting Update publication highlights key trends in SEC staff comment letters issued during the year ended 30 June 2021, including comments on accounting and disclosures related to the COVID-19 pandemic, the use of non-GAAP measures, management's discussion and analysis and revenue recognition. Publication date: 12 Mar 2021. us SEC Comment Letter Trends. Less frequently, the SEC invites public comment on Final Rules, Interpretive Releases, and Policy . For a discussion of SEC comment letters on additional topics, see the following Deloitte publications: • SEC Comment Letters — Including Industry Insights: A Recap of Recent Trends, Eighth Edition (November 2014). Chapter 6 — Industry-Specific Topics. Under ASC 740-30-50, companies must disclose the amount of earnings reinvested permanently and the amount of estimated tax on hypothetical repatriation of such . 9 Based on its allocation of staff resources, Corp Fin views filing reviews as a substantial activity. Send 3 copies of your paper comment letter to: Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609. The SEC staff has focused on the quality of the disclosure around significant judgments and estimates associated with goodwill and intangible assets, including impairment assessments, frequently commenting on: the identification of reporting units . In addition to extracts of letters and links to relevant . Share. We collect data on comment letter conversations from the Audit Analytics database of SEC comment letters. The Division of Corporation Finance selectively reviews filings made under the Securities Act and the Exchange Act to monitor and enhance compliance with applicable disclosure requirements. s 145 Appendix D: Deloitte Resource. View image. Home. Summary of Comment Letters for the SEC's Climate Risk Disclosure RFI. CiteSeerX - Document Details (Isaac Councill, Lee Giles, Pradeep Teregowda): Highlighting RisksTo our clients, colleagues, and other friends: We are frequently asked to provide our perspective on the topics the SEC staff focuses on in its comment letters to registrants. The sample includes SEC comment letters issued from 2004 through 2014 where at least one comment was issued in relation to a 10-K filing. 10 Notwithstanding this view, whether or not the comment letter process results in substantive disclosure changes with favorable implications for firms' informational . SEC Comment Letters | Deloitte US SEC Comment Letter includes extracts of frequently issued SEC staff comments, additional analysis, and links to resources that are relevant to SEC filers. . Recognizing that "investor demand for, and company disclosure of information about, climate change risks, impacts, and opportunities has grown dramatically," former Securities and Exchange Commission (SEC or Commission) Acting Chair Allison Herren Lee released 15 . The 2017 study notes a decline in the overall number of SEC . The comment letters received on the proposed roadmap generally support the SEC's goal of a single, widely accepted set of high-quality accounting standards; however, views differ on how to achieve this goal. This site uses cookies to provide you with a more responsive and personalised service. Response 1 of 7: I had an unplanned C section after 25 hours of labor followed by a planned C section with my second. Comment Examples. Christine Davine, partner and national director of SEC services at Deloitte, said about half of all public companies are reviewed in a given year, with about a third of those reviews resulting in comment letters. Comment Letters to Cintas. If you are currently a domestic registrant, you might be interested in the fifth edition of our companion publication, SEC Comment Letters Including Industry Insights — Improving Transparency. 1. . A total of 38 companies have been issued comment letters, 8 of which are early adopters of the new revenue standard. By Nicola M. White. We appreciate the opportunity to provide comments to the Securities and Exchange Commission . As shown in the chart below, most of the letters were uploaded during the second half of 2018, with more trickling in throughout 2019. SEC Comment Letters — Statistics According to "Edgar," a supplement to the ninth edition of our comment letter publication, would not have been possible without the significant contributions of the Accounting Services, Audit Policy, Methodology and Standards, and SEC Services departments and the industry specialists at Deloitte & Touche LLP. s 150 Appendix E: Glossary of Standards and Other Literature. In several comment letters to issuers as part of its disclosure review process, the SEC alerted companies to concerns about reporting on everything from taxes to unconventional measures. The sample comments, which the SEC has published before publicly releasing any of the recently issued company-specific . Using the Fog index to DO NOT submit attachments as HTML, GIF, TIFF, PIF, ZIP, or EXE. Both provide insightful analysis of the major trends and issues in SEC Comment Letters. We have now published a third edition that reflects new topics and updates existing topics to reflect new areas that the SEC staff has commented on since the February 2009 edition. Deloitte's Roadmap: SEC Comment Letter Considerations, Including Industry Insights. SEC Accounting & Reporting Requirements Paper. The Division of Corporation Finance selectively reviews filings made under the Securities Act and the Exchange Act to monitor and enhance compliance with applicable disclosure requirements. of which the AICPA Conference is a prime example. 6.5 Technology, Media, and Telecommunications. Overview. SEC rulemaking. Market regulators Monday gave the first glimpse into the scrutiny they are giving companies about the business risks of . Companies argued material information already in 10-Ks. quality, we use tax-related SEC comment letters and their ultimate resolutions. Applicability. In addition to providing our insights on the nature of the SEC staff comments, we provide sample text from the SEC staff's comments and . 2 SEC Comment Letters — Including Industry Insights Business Combinations Purchase Price Allocation Example of an SEC Comment [P]lease provide for us the total purchase price of the 2012 acquisitions, details of the purchase . Publication date: 21 Dec 2017. us PwC comment letter. This compares with three-quarters of company filings generating comments about a decade ago. Deloitte Touche Tohmatsu August 26, 2008 Securities and Exchange Commission Attn: Florence Harmon, Acting Secretary . LinkedIn . The following illustrative letter contains sample comments that the Division may issue to companies regarding their climate-related disclosure or the . Comment Letters. The purpose of this study is to identify important SEC comment letters and examine the mechanisms by which they a ect rm value. An emerging literature shows that shareholders benefit from the Securities and Exchange Commission's (SEC) filing reviews in terms of improved disclosures and reduced information asymmetry. receiving any comment letter ("No-letter Firms") modify their subsequent year's disclosures to a larger extent if the SEC has commented on the risk factor disclosure of (1) the industry leader, (2) a close rival, or (3) numerous industry peers. Recent comments from regulators and standard setters may help issuers identify areas for improvements in existing income taxes disclosures to provide more robust and relevant information to investors. Recent examinations of the comment letters indicate that the Commission is taking a harder look at revenue recognition, loss contingencies, segmentation . OR 3. The SEC staff's reviews related to filings have centered heavily on MD&A. The sixth edition of SEC Comment Letters — Including Industry Insights: Highlighting Risks offers such perspective. SEC staff asked mostly the same questions of Cintas, which does about $7.1 billion in sales annually selling corporate uniforms as well as assorted cleaning supplies (mops, mats, first aid kits, restroom materials, and so forth). s 160 The 2017 study notes a decline in the overall number of SEC reviews with comment letters and in the number of SEC comments issued over the past several years. Comment letter reviews have been conducted as long as the SEC has existed. The SEC staff also began providing comment letters by e-mail for the first time this year and has reduced the time it takes to make comment letters (and related correspondence) publicly available on EDGAR from 45 days to 20 days after a review is completed. Each copy must list the "File Number" for the rule. From time to time, the SEC invites comments from the public on Proposed Rules, Concept Releases, Self-Regulatory Organization filings, Public Company Accounting Oversight Board Rulemaking, Rulemaking Petitions, and Other Releases. You are here. Deloitte Publications. Deloitte's US GAAP Plus Web site is a resource you can use to keep current on the SEC's latest activities related to financial . The 2017 study notes a decline in the overall number of SEC . In November 2017, Deloitte & Touche LLP released its annual study on the Securities and Exchange Commission's ("SEC") recent comment letters. Regulator asked Cintas, Matson for climate risk detail. ASC 606 was adopted by a small number of early adopters last year. Deloitte Publications. Editor's Note: In speeches, Mr. Higgins and other SEC staff members have asked registrants to carefully consider whether their decisions to disclose information are based solely on industry-specific or other SEC comment trends that are identified as "hot button" issues. The Deloitte study highlights the significant increase in 2016 in SEC comments regarding non-GAAP financial measures, which is no surprise in light of the SEC's public comments regarding this issue and the new SEC guidance (C&DIs) released in May 2016, and is consistent with trends we have been seeing. CiteSeerX - Document Details (Isaac Councill, Lee Giles, Pradeep Teregowda): We are frequently asked to provide our perspective on the topics the SEC staff focuses on in its comment letters to registrants. . I vote planned C. This publication contains extracts of frequently issued SEC staff comments, analysis of those extracts, and links to resources that are relevant to SEC filers. KPMG has seen an increase in SEC comments asking how companies are complying with S-X Rule 5-03.2, SAB Topic 11.B and SAB Topic 14.F in their income statements: S-X Rule 5-03 requires companies to state separately net sales and gross revenues, and applicable costs and expenses related to tangible products sold; public utility operating revenues . 27:29 - Segment reporting. SEC Comment Letter Publication | DART - Deloitte Accounting Research Tool. Deloitte & Touche LLP +1 720 264 4866. mburley@deloitte.com.

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