Deloitte’s recently updated "SEC Comment Letters - Including Industry Insights" includes: (i) an update on the SEC’s strategic priorities; (ii) a summary of comment letter trends relating to the top 10 topics of frequent comment in the year ended July 31, 2024, along with various comment letter statistics; and (iii) an analysis of SEC staff comments and corresponding comment letter excerpts and insights covering the gamut of top-of-mind financial statement and SEC disclosure topics, including MD&A, risk disclosure, non-GAAP financial measures, disclosure controls & procedures, internal control over financial reporting (ICFR), and executive compensation and other proxy disclosures.
Also included in the appendix: (a) the SEC staff’s review and comment letter process, (b) best practices for working with SEC staff, and (c) helpful tips on searching the SEC’s EDGAR database for comment letters.