Who are the attorneys that do the most work in helping their clients respond to SEC Comment Letters? In a recent post, we looked at some of the law firms that were frequently named in SEC comment letters. In this post, … Continue reading
Category Archives: SEC Comment Letters
Is the SEC Captured? Evidence from Comment Letter Reviews
In this post, we look at a recent academic paper titled “Is the SEC Captured? Evidence from Comment-Letter Reviews”. Using Audit Analytics’ SEC Comment Letter database, the authors, Jonas Heese, Mozaffar Khan, and Karthik Ramanna, research if having political connections (PC) creates a … Continue reading
SEC Comment Letters: A Six Year Trend
In this annual blog, we aim to discuss macro trends in SEC Comment Letters issued between 2010 and 2016. We typically focus on comments related to annual and quarterly filings of 10-K filers. This year, however, we provide some insight … Continue reading
The People of SEC Comment Letters: 2016
The data found in SEC Comment Letters can offer insight into some overlooked areas of a company’s business. In the past year, we have discussed a continuous decline in the number of letters and major areas of concern raised by the … Continue reading
Could the MDC Partners Enforcement Action have been Predicted?
How likely is a company to be cited for a violation of non-GAAP reporting rules? Is non-GAAP violation a primary offense? That is, can a company face an enforcement action just for that? Let’s take a look at a recent … Continue reading
EBay Reports Material Weakness: Second Control Deficiency in Three Years
Last week on February 6, in its Fiscal 2016 10-K, eBay (EBAY) disclosed a material weakness in its internal controls over financial reporting (“ICFR“). The deficiency related to a failure to properly apply tax accounting and affected the Deferred Tax Asset and Income Tax Benefit … Continue reading
SEC Comment Letters: Early Returns
Note: This post features a guest contribution from our friend Jack Ciesielski, the publisher of the Analyst’s Accounting Observer. Together with our friends at the Analyst’s Accounting Observer, we reviewed the first batch of the SEC’s Division of Corporation Finance non-GAAP comments. The blog … Continue reading