DLA Piper's memo on SEC comment letter trends and shareholder engagement disclosure identifies in a user-friendly manner the SEC's top comment letter topics, and the most commonly occurring comment topics relating to MD&A (the most frequent comment area) for the period October 1, 2017 through September 30, 2018, as shown here:
The memo also includes takeaways and tips on select areas of Staff focus for the top four comment generators - MD&A, revenue recognition, non-GAAP, and fair value - and suggested financial reporting-related action items.
See also these recent reports on comment letter trends, examples and insights here ("SEC Comment Letter Trends & Examples"/PwC), here ("SEC Comment Letter Trends & Insights"/EY), and here ("SEC Comment Letter Trends"/Audit Analytics), and additional resources on our Financial Reporting page.
This post first appeared in the weekly Society Alert!