Deloitte’s recently released and always-eagerly-anticipated "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, 2017 - along with various comment letter statistics; and (iii) an analysis of SEC staff comments and corresponding comment letter excerpts covering the gamut of top-of-mind disclosure topics including non-GAAP financial measures, revenue recognition, cybersecurity, ICFR and DC&P, and executive compensation and other proxy disclosures.
Also included are appendixes on: (i) the SEC staff’s review and comment letter process, (ii) best practices for working with SEC staff, and (iii) helpful tips on searching the SEC’s EDGAR database for comment letters.