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
Category Archives: SEC Comment Letters
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
Kingsway Financial Services, Inc. [KFS]: Extensive SEC Comment Letter Conversation Identifies Accounting Errors
Kingsway Financial Services, Inc. [KFS] was forced to restate financial statements to correct revenue recognition errors related to adoption of ASC 606 and its effect on warranty subscriptions and commissions The restatement was triggered by a 15-letter comment letter conversation … Continue reading
PayPal: SEC Requests Clarification about TIO Intangibles
In August 2018, the SEC issued comments to PayPal Holdings Inc. [PYPL] requesting clarification about the value of intangible assets recorded during the acquisition of TIO Networks. In July 2017, PayPal acquired Canadian payment-processing company TIO Networks for $238 million. … Continue reading