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SEC Comment Letter Trends & Examples

By Randi Morrison posted 05-27-2024 06:32 PM

  

PwC's online "SEC comment letter trends" for the period April 1, 2023, through March 31, 2024, is a consistently great tool that allows online exploration of recent Form 10-K and 10-Q comment letter trends and samples by industry or comment letter topic, and provides easy access to topically relevant guidance.

Notably, based on an Audit Analytics analysis of comment letters for the 12 months ended March 31, 2024, compared to the 12 months ended March 31, 2023, the relative number of comment letters year-over-year on MD&A declined, whereas the relative number of comment letters on all other topics tracked, including non-GAAP measures and disclosure controls & ICFR, generally remained flat year-over-year. Comment examples by topic (non-GAAP measures, for example) are accessible with one click.

See industry-specific comment letter trends for the same period by clicking on the specific industry here and PwC's suggested practices on responding to comment letters here.

Access additional information & resources on our Financial Reporting page.

                              This post first appeared in the weekly Society Alert!

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