The trends we have observed with SEC comment letters over the past several years have continued. Through the first half of 2021 comment letters that reference 10-Ks, 10-Qs, or 8-Ks are on pace to decline by about 15% compared to … Continue reading
Category Archives: SEC Comment Letters
How the SEC’s Focus on Climate Change Might Affect Comment Letters
On Wednesday, Acting SEC Chair Allison Herren Lee directed the Division of Corporation Finance to begin focusing on climate-related disclosures. This is the first action the SEC has taken to address climate-related disclosure since the Commission’s 2010 Interpretive Guidance. The … Continue reading
SEC Comment Letters: A Nine Year Trend
A review of SEC comment letters on forms 10-K, 10-Q, and 8-K shows that the trend of comment letters has continued to decline. Between 2018 and 2019, the number of comment letters fell by roughly 30%; similarly, between 2017 and 2018, there … Continue reading
SEC Eyes Impairment Testing in Comment Letter Amid Pandemic
Last week, the Securities and Exchange Commission (SEC) released a comment letter to Carlisle Companies Incorporated [CSL] – a global diversified manufacturing company – asking the Company to expand on its disclosure regarding impairment testing in Q1 2020. Carlisle’s annual … Continue reading
Reasons for an Amended 10-K: 2019
Form 10-K, an annual report filed by US-based public registrants, is the most comprehensive source of information regarding a company’s financials and its underlying business. These reports are thoroughly scrutinized by investors and other users, which explains why they need … Continue reading
SEC Comment Letters: An Eight Year Trend
The total amount of comment letters stemming from 10-K and 10-Q filings has once again decreased (as shown in the chart below). From 2017 to 2018, total comment letters decreased by roughly 26%, which is slightly steeper than the decline we’ve … Continue reading
Shutdown Slows Comment Letters, IPOs
On Friday, January 25th, 2019, President Trump signed a bill to reopen the federal government [temporarily] for three weeks, putting an end to the longest government shutdown in U.S. history. The following day, SEC Chairman Jay Clayton released a statement … Continue reading