PwC's online "SEC comment letter trends" for the period 10/01/21 to 09/30/22 is a great tool that allows online exploration of recent comment letter trends and samples by industry or comment letter topic, and easy access to topically relevant guidance.
Notably, based on an Audit Analytics analysis of comment letters for the 12 months ended September 30, 2022, compared to the 12 months ended September 30, 2021, the relative number of comment letters on climate change-related risk factors, MD&A, and business combinations increased year-over-year, whereas revenue recognition comments declined. The relative number of comment letters on non-GAAP measures; fair value measurement; inventory and cost of sales; disclosure controls and ICFR; and debt, quasi-debt, warrants and equity, remained flat year-over-year.
See industry-specific comment letter trends here; PwC's best practices on responding to comment letters here; and the firm’s “Don’t wait until the SEC staff asks you about climate change,” which—among other things—summarizes the SEC’s 2010 climate change disclosure guidance and provides examples of initial and follow-up comments from SEC staff on issuers’ climate-related disclosure (or the absence thereof).
Access additional information & resources on our Financial Reporting page.
This post first appeared in the weekly Society Alert!