Added Perspective

SEC Comment Letters—Including Industry Insights, What 'Edgar' Told Us

November 4, 2015

By Deloitte

This new release in Deloitte’s SEC Comment Letter series includes extracts of frequently issued Securities and Exchange Commission staff comments, additional analysis, and links to resources that are relevant to SEC filers. The ninth edition features:


  • Statistics identifying the top 10 topics addressed in SEC comment letters during the 12 months ended July 31, 2015.
  • Recent topics of focus related to MD&A, financial statement accounting, and other disclosures, including:
    • Disclosure of known trends or uncertainties in registrants' results of operations.
    • Fair value, including disclosures about valuation techniques and inputs used to determine fair value.
    • Revenue recognition, including the principal-versus-agent analysis.
    • Non-GAAP financial measures and key metrics.
    • Segment reporting, particularly (1) the identification of a registrant’s chief operating decision maker and operating segments and (2) the basis for the aggregation of operating segments.
    • Evaluation of the potential severity of errors and deficiencies to determine whether there is a material weakness in internal control over financial reporting.
    • Liquidity risks and restrictions on a registrant’s ability to transfer cash or pay dividends.
  • Appendixes offering insights into past SEC comment letter trends, 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.


To read Deloitte's SEC Comment Letters—Including Industry Insights, What "Edgar" Told Us, Ninth Edition, report, click here



Most Read

10 Things
10 read in summer 2024

It's the Summer Solstice, and that means that for most of us the sun is shining, temperatures are heating up, and longer days allow for pursuits ...

Top of the Agenda - Compensation
Fund board pay increases in 2023, MPI survey says

Independent mutual fund directors saw an increase in compensation in 2023, on average, although actual compensation levels and percentage adjustments in compensation continue to vary widely ...