In each of the past three years, the SEC has reviewed the filings of more than half of all public companies. In its 2015 Agency Financial Report, for example, the SEC disclosed that it reviewed 51% of public companies last year … Continue reading
Category Archives: SEC Comment Letters
Common Topics in IPO Comment Letters
Taking a company public can be a long and difficult process. An IPO can easily take a year or more to complete, and the preparations can begin long before a formal S-1 is filed. Then, once filed, an S-1 has to … Continue reading
Non-GAAP Metrics in SAB 99 Materiality Analyses
The pros and cons of non-GAAP metrics have been discussed in more than a few recent articles. Proponents of non-GAAP frequently claim that GAAP contains many ambiguities and loopholes, and that non-GAAP metrics can be more current and relevant. Opponents sometimes … Continue reading
SEC Staff Addresses Developments in Pension Accounting
At last week’s AICPA Conference on Current SEC and PCAOB Developments, the topic of pension accounting came up more than once. In one session, Ashley Wright, a Professional Accounting Fellow in the SEC’s Office of the Chief Accountant, discussed a recent … Continue reading
2015 SEC Comment Letters: Trends and Issues, a 3 Year Comparison
For the sixth consecutive year, there has been a steady decline in the total number of comment letters issued by the SEC. In the first half of 2015, 2,877 10-K and 10-Q comment letters (1,690 UPLOADs and 1,187 CORRESPs) were filed … Continue reading
Fair Value Estimates and SEC Comment Letters
The Impact of SEC Disclosure Monitoring on the Uncertainty of Fair Value Estimates, by Daniel Bens, Mei Cheng, and Monica Neamtiu, (2015 Accounting Review, forthcoming) examines the effectiveness of SEC comment letters to increase transparency in fair value estimates disclosures. The authors postulate … Continue reading
Longest Comment Letter Conversations: A Five Year Analysis
In one of our recent posts, we noted that the average SEC comment letter conversation for 2014 consisted of 3.9 letters and lasted 48 days, significantly less than the 5 letters and 86 days we calculated for 2010. In this blog, we attempt to … Continue reading