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SEC Comment Letters — Including Industry Insights (2017)

Published on: 09 Nov 2017

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 2017 edition features:

  • An update on the SEC’s priorities.
  • A summary of comment letter trends related to the top 10 topics of frequent comment in the 12-month period ended July 31, 2017, along with various comment letter statistics.
  • Recent topics of focus related to disclosures associated with financial statement accounting, SEC reporting, initial public offerings, foreign private issuers, and industry-specific matters, including:
    • Non-GAAP financial measures and key metrics.
    • Disclosures of known trends or uncertainties in registrants’ results of operations
    • Fair value, including disclosures about (1) valuation techniques and inputs used to determine fair value and (2) the use of third-party pricing services.
    • Segment reporting, particularly (1) the identification and aggregation of operating segments, (2) changes in reportable segments, and (3) entity-wide disclosures.
    • Revenue recognition, including SAB 74 disclosures related to the adoption of the new revenue standard.
    • State sponsors of terrorism.
  • Appendixes offering (1) insights into the SEC staff’s review and comment letter process, (2) best practices for working with the SEC staff, and (3) helpful tips on searching the SEC’s comment letter database.

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