All Comment Letters articles
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BlogAmazon pushes back on SEC revenue disclosure comment
The SEC is getting some pushback from Amazon over how it breaks up and reports revenue for its different streams under ASC 606.
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Article
Struggling with segment reporting? Relief may be coming
Long a thorn in the side of preparers and regulators alike, segment reporting rules may finally be getting a tune-up designed to make compliance more straightforward.
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Article
Revenue 2.0: Work continues to adapt to new rules
Even after calendar-yer companies have filed their first-quarter reports reflecting a new way to recognize revenue, work continues to adapt to the new rules.
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Blog
For early revenue adopters, SEC digs into year-end disclosure
SEC staff are showing an interest in some specific disclosures companies are providing under the new revenue standard, based on themes emerging in comment letters.
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Blog
SEC hones in on non-GAAP in 2016 comment letters
The SEC focused its comment letters in 2016 on non-GAAP reporting more than any other topic, surpassing even MD&A, the perennial favorite area of focus.
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Blog
SEC comments on leasing expected this year-end
If history is any indicator, companies can expect the SEC to begin scrutinizing disclosures about the pending new lease accounting requirements at this year-end.
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Article
Comment letters with no response
Nobody likes to get a comment letter from the SEC, but what happens when you don’t respond or comply with one? Mercedes Erickson has the answers.
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Blog
Say goodbye to 'Tandy' language in comment letters
Tandy representations—an attestation that comment letter reviews by SEC staff cannot be used as a legal defense—are no longer needed in filings, according to new guidance from the Division of Corporation Finance.
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Article
Comment Letter Conversations Get a Bit Easier
Those awkward conversations you have with SEC staff when they comment on your periodic filings? They’re getting easier. The number of comment letter conversations has fallen 50 percent in the last five years, suggesting overall improvement in financial reporting. “Obviously internal controls have gotten better at companies, and that certainly ...