SEC Comment Letters on Domestic Registrants (Third Edition)

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03 Dec 2009

In January 2008, Deloitte (United States) published two Special Reports analysing the comments by the staff of the US Securities and Exchange Commission on the financial statements of registrants.

One of the 2008 reports reviewed comments on domestic registrants using US GAAP. The other reviewed comments on foreign private issuers using IFRSs. And in February 2009, Deloitte published a revised edition of the first report:   SEC Comment Letters on Domestic Registrants: A Closer Look (PDF 810k). 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. The SEC staff has continued to issue comments on all topics included in that edition, such as revenue recognition, business combinations, segment reporting, financial instruments, and impairments. In addition, in light of the troubled credit markets, the staff has continued to closely scrutinize goodwill and intangible asset impairments, other-than-temporary impairments, deferred tax valuation allowances, pension liabilities, executive compensation disclosures, MD&A disclosures, debt covenant compliance, fair value disclosures, and the allowances for loan losses, just to name a few. New to this third edition are sections on the following industries:
  • Financial services, including the banking, securities, and real estate industries
  • Energy and resources, including the power and utilities and oil and gas industries
  • Health sciences, including the health care and life sciences industries
  • Consumer and industrial products, particularly the retail industry
Click to download SEC Comment Letters on Domestic Registrants: A Closer Look (Third Edition) (PDF 2,589k).


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