Further to our recent reports (see here, here and here: "SEC Looking For…), Jim Hamilton's World of Securities Regulation informs that SEC Staff is focused on companies' cybersecurity, Brexit and LIBOR transition-related risk disclosures. On cyber, Corp Fin Director Bill Hinman reportedly emphasized an expectation of tailored (i.e., non-boilerplate) cybersecurity disclosure and companies' consideration of their insider trading policies in the context of the SEC's 2018 cybersecurity disclosure guidance, and noted that Staff is observing more board oversight disclosure.
Corp Fin Chief Accountant Kyle Moffatt reportedly said Staff is focused on controls & procedures relative to the use of non-GAAP measures; if Staff believes non-GAAP measures are being used simply to "dress up the numbers," it will seek additional disclosure from the company as to why the measures are important.