2013 technology sector SEC comment letter trends

December 2013
  • Print-friendly version
2013 technology sector SEC comment letter trends

At a glance

As year-end rapidly approaches, it is time to plan for your annual filing. PwC's technology industry publication, Stay informed: 2013 technology SEC comment letter trends, provides a comprehensive analysis of recent SEC staff comments to assist you with the understanding of the key trends that are relevant to companies in the technology sector.

We have analyzed over 2,000 comments issued by the SEC staff from July 1, 2012 to June 30, 2013 to 254 companies in the following subsectors: software and internet, computers and networking, and semiconductors. There was a 27% increase in the overall number of comments received when comparing 2013 to 2012; this appears to be driven by an increase in the number of companies reviewed, as the average comments per filer decreased slightly. The main areas of focus by the staff did not change significantly.

View SEC staff comments by topical area

We hope that taking a deeper dive into each of these key trends, along with specific examples of comments, will provide you with valuable insights and aid in your production of high quality annual reports.

Click the headings below to explore further analysis on technology SEC comment letter trends.

Social media engages the investor

More than ever, companies are connecting to their customers through social media tapping into their likes and dislikes, creating intimate experiences to rapidly evolve their products and fine-tune their marketing efforts. We have started to see companies use social media to engage with their investors in the same way they have been using social media to connect with their customers. As a result, social media outlets have become new communication platforms for the SEC to monitor.

Revenue recognition comments

Revenue recognition for technology companies continues to be an area of complexity and judgment. For 2013, revenue recognition-related comments accounted for nearly 10% of all comments received. Multiple-element arrangements and software revenue recognition continue to be at the top, but revenue recognition in the virtual environment is gaining momentum as online gaming has been a rapidly growing segment of the technology industry.

Other notable trends

We provide additional analysis of other notable trends in SEC comment letters. Many of the comments relate to areas other than financial accounting such as compliance, controls and procedures, and risk factors. More recently, as technology companies expand their operations internationally, there has been a general increase in focus on disclosure of operations in locations identified as state sponsors of terrorism.