An article in today’s New York Times reports on a potentially troubling phenomenon of tech companies increasingly using non-GAAP numbers to promote financial performance. “Tech Companies Fly High on Fantasy Accounting“, quoting analysts and investors, further reports that the cumulative … Continue reading
Category Archives: SEC Comment Letters
Walmart Reports Material Weakness
In a 10-Q filed yesterday, September 9th, Walmart disclosed a significant deficiency that rose to the level of material weakness in its SOX Section 302 Disclosure Controls and Procedures assessment. The deficiency related to the company’s application of lease accounting. According to … Continue reading
2014 SEC Filing Highlights, Part 1 of 2
In this post we kick off what we hope will be an annual series. It is a full-year recap of some of the most notable SEC disclosures that we track: a “best-of-the-year” review. In this first post, we’ll look at the largest restatement; the … Continue reading
SEC Makes No-Review Letters Public
The SEC has announced that, beginning July 1, 2015, it will release “no-review” letters to the general public through the EDGAR system. Before this announcement, these letters were only available through Freedom of Information Act requests. The SEC Division of … Continue reading
Auditors Copied on SEC Comment Letters
SEC Comment Letters are a rich vein of data on companies and their operations. For the average investor, however, that data is difficult to mine. The total volume of communication can be quite substantial, and the letters are often dense. Few stakeholders have the time … Continue reading
SEC Comment Letters: A Five Year Trend
As we discussed in one of our previous posts, the number of SEC comment letters referring to issues in 10-K and 10-Q filings decreased about 25% in the first half of 2014, compared to the same period in 2013. But what about previous … Continue reading
Genworth Financial Cites Inadequate Controls
Reporting requirements may sometimes seem to be set in stone, but they do in fact change from time to time. Usually, when a regulator changes a requirement, it also imposes a deadline for the implementation of the change. The companies are … Continue reading