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Category Archives: SEC Comment Letters

The Audit Analytics Comment Letter Threads database arranges SEC comment letter narratives into threads of numbered SEC comments matched with corresponding response and follow up questions between the SEC staff and registrant. These threads capture the initial SEC comment to the final resolution of accounting and legal issues.

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Terrorist Nation and OFAC Violations – SEC Comment Letters

Posted on June 11, 2014 by Olga Usvyatsky

Last week rumors hit the Street that BNP Paribas (EPA:BNP), one of the largest French banks, would settle with the US Department of Justice for a record $5 billion (or even $10bn, according to different sources). BNP is also facing criminal … Continue reading →

Posted in Corporate + Legal, Regulation Oversight, SEC, SEC Comment Letters

2013 Comment Letters Trends and Analysis – Issues Breakdown

Posted on May 12, 2014 by Olga Usvyatsky

The Sarbanes-Oxley Act of 2002 requires the SEC to review the financial statements of every public company at least once every three years, while permitting more frequent reviews as needed. According to the SEC 2013 Annual Report, the agency reviewed … Continue reading →

Posted in Corporate + Legal, SEC, SEC Comment Letters

SEC: Taxes in Season

Posted on January 27, 2014 by Olga Usvyatsky

Last Friday, the Wall Street Journal published an interesting piece from Emily Chasan about the SEC, taxes and comment letters. In that article, Ms. Chasan reported that the SEC grilled a number of companies on their disclosures regarding the possible … Continue reading →

Posted in Corporate + Legal, Indefinitely Reinvested Foreign Earnings, SEC Comment Letters, Tax

SEC Comment Letters: Good Question, Let me Think About It

Posted on November 20, 2013 by Olga Usvyatsky

Interviewing for a job is something almost everyone has experienced. Some have done more, others less, but either way it is a fairly routine matter. A candidate sends in a resume, prepares a narrative, dresses up, appears on time and the … Continue reading →

Posted in Corporate + Legal, Late Filings, Regulation Oversight, SEC Comment Letters

SEC Law Firms: Comment Letter Activity

Posted on September 9, 2013 by John Pakaluk

Imagine a CFO walking into his office to start the day. As he puts down his cup of coffee, he notices an envelope placed on his keyboard, where he can’t miss it. On the envelope is the unmistakable seal of … Continue reading →

Posted in Corporate + Legal, Law Firms, Market Share, SEC Comment Letters

Restatements: Where They Come From

Posted on August 2, 2013 by Olga Usvyatsky

Ever since the days of Enron, financial restatements have been considered big news. Not all accounting mistakes are created equal, of course: thousands are discovered every year, but most are not material enough even to warrant a disclosure. A few, … Continue reading →

Posted in Audit + Compliance, Financial Restatements, SEC Comment Letters

Increased SEC Scrutiny Over Sovereign Debt Disclosure

Posted on March 26, 2013 by Jessica Fritz

As severe financial crisis has spread from Greece to larger countries such as Spain and Italy, voices warning against exposure to sovereign debt have gotten louder. The Cypriot government’s attempt to impose up to a 9.9% tax on bank deposits … Continue reading →

Posted in Corporate + Legal, SEC Comment Letters

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