Deloitte’s "SEC Comment Letter Considerations, 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, 2020, 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 risk factors and complex and evolving risks, non-GAAP financial measures, ICFR and DC&P, and executive compensation and other proxy disclosures. Also included are appendices on the SEC staff’s review and comment letter process, best practices for working with SEC staff, helpful tips on searching the SEC’s EDGAR database for comment letters, and more.
See our recent report: "SEC Comment Letter Trends & Examples" and additional resources on our Financial Reporting page. This post first appeared in the weekly Society Alert!