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Category: SEC Comment Letters

SEC Comment Letters: A Nine Year Trend

August 19, 2020 admin Corporate + Legal, SEC Comment Letters Leave a comment

A review of SEC comment letters on forms 10-K, 10-Q, and 8-K shows that the trend of comment letters has continued to

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SEC Eyes Impairment Testing in Comment Letter Amid Pandemic

June 22, 2020 admin Coronavirus, Corporate + Legal, SEC Comment Letters Leave a comment

Last week, the Securities and Exchange Commission (SEC) released a comment letter to Carlisle Companies Incorporated [CSL] – a global diversified

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Shutdown Slows Comment Letters, IPOs

February 5, 2019 admin Initial Public Offerings (IPO), SEC, SEC Comment Letters Leave a comment

On Friday, January 25th, 2019, President Trump signed a bill to reopen the federal government [temporarily] for three weeks, putting an

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PayPal: SEC Requests Clarification about TIO Intangibles

January 4, 2019 admin Accounting + Oversight, SEC, SEC Comment Letters Leave a comment

In August 2018, the SEC issued comments to PayPal Holdings Inc. [PYPL] requesting clarification about the value of intangible assets recorded

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Ollie’s Bargain Outlets’ Elimination of Critical Accounting Disclosure Draws SEC Attention

December 11, 2018 admin Accounting + Oversight, Accounting Estimates, SEC, SEC Comment Letters Leave a comment

Retailer Ollie’s Bargain Outlet Holdings, Inc. [OLLI] recently drew the SEC’s attention when the company said it would eliminate all of

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A Look at Top SEC Comment Letter Issues in 2018

December 4, 2018 admin Non-GAAP, Revenue Recognition, SEC, SEC Comment Letters, Tax Leave a comment

The number of SEC comment letters has been declining for nine consecutive years. During the first nine months of 2018, 2,174

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SEC Registrants with Poor Cyber Controls

November 8, 2018 admin Cybersecurity, Internal Controls (ICFR - SOX 404), SEC, SEC Comment Letters Leave a comment

On October 16, 2018, the SEC’s Division of Enforcement issued an investigative report regarding cyber-related fraud’s effect on public company internal

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Insurance Industry Sees Rise in Negative Events

October 30, 2018 admin Accounting + Oversight, Insurance Industry, Quality of Reporting, SEC, SEC Comment Letters Leave a comment

There have been several negative events within the insurance industry over the past few years. In 2017, there were 18 restatements

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Trends in SEC Non-GAAP Comment Letters 2016-2018

October 16, 2018 admin Non-GAAP, SEC, SEC Comment Letters Leave a comment

Key Findings The overall number of comment letters issued by the SEC has decreased since 2010 The percentage of comment letters

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Due Diligence with Audit Analytics

September 26, 2018 admin Audit Fees, Audit Opinions, Financial Restatements, SEC Comment Letters Leave a comment

Dixon Hughes Goodman LLP on Audit Analytics Headquartered in Charlotte, NC, Dixon Hughes Goodman LLP boasts over 2,000 employees and ranks

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Audit Analytics for Regional Accounting Firms

September 19, 2018 admin Director & Officer Changes, Financial Restatements, Internal Controls (ICFR - SOX 404), Litigation, SEC, SEC Comment Letters Leave a comment

Frazier & Deeter LLC is a full-service accounting firm, headquartered in Atlanta, Georgia. Operating across all industries, Frazier & Deeter offers

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Literature Review: “The Effect of Enforcement Transparency: Evidence from SEC Comment-Letter Reviews”

August 13, 2018 admin Academic Literature, Quality of Reporting, Regulation, SEC Comment Letters Leave a comment

In recent years, more attention has been given to policies surrounding transparency in financial reporting practices, such as banks disclosing results

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SEC Comment Letters: A Seven Year Trend

July 13, 2018 admin Non-GAAP, SEC Comment Letters Leave a comment

It is time once again to look at macro trends in SEC Comment Letters. As with every year we will look

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SEC’s Focus in IPO Comment Letters

July 9, 2018 admin Initial Public Offerings (IPO), SEC, SEC Comment Letters Leave a comment

In a January 2016 post, we examined trends in IPO comment letters between 2013 and 2015, including several metrics designed to

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SEC Comment Letters Every Analyst Should Read

May 14, 2018 admin Corporate + Legal, Non-GAAP, Sarbanes-Oxley, SEC Comment Letters Leave a comment

As part of its requirements under the Sarbanes-Oxley Act of 2002, the SEC reviews the financial reporting of every public company

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Reasons for an Amended 10-K: 2017

March 14, 2018 admin Financial Restatements, Internal Controls (ICFR - SOX 404), Red Flags, SEC Comment Letters Leave a comment

Annual reports, or 10-Ks, are known for their extensive information relating to all aspects of a company’s business. With that being

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Non-GAAP Reporting One Year After New SEC Guidance

December 21, 2017 admin Non-GAAP, SEC, SEC Comment Letters Leave a comment

Audit Analytics released our latest report, Corporate Implementation of SEC’s Compliance & Disclosure Interpretations Regarding Non-GAAP Financial Measures, at this year’s annual AICPA conference on current

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A Look at Top SEC Comment Letter Issues in 2017

December 4, 2017 admin Non-GAAP, Revenue Recognition, SEC, SEC Comment Letters Leave a comment

2017 marked the eighth consecutive year of decline in the number of SEC comment letters. During the first six months of

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Top Five to Celebrate First Five

October 27, 2017 admin Audit Fees, Auditor Changes, Cybersecurity, Director & Officer Changes, Financial Restatements, Initial Public Offerings (IPO), Litigation, Revenue Recognition, SEC Comment Letters Leave a comment

We published our first blog post in October of 2012. Over the past five years, our analysts have shared their insights into

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Axon Enterprise, “The Dog ate my Email”

October 23, 2017 admin SEC Comment Letters Leave a comment

Technology has greatly improved our lives. Without it, we wouldn’t be able to surf the net, track our steps, talk through

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SEC Updates Non-GAAP C&DIs for Business Combinations

October 18, 2017 admin Litigation, Mergers & Acquisitions, Non-GAAP, SEC Comment Letters Leave a comment

On October 17, 2017, the SEC released two new updates to the Compliance & Disclosure Interpretations (“C&DIs”). The C&DIs comprise the Division’s

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