Financial Services: 2015 SEC comment letter trends


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This paper discusses the recent areas of focus and applicable accounting or reporting guidance in SEC staff’s comment letters issued over the past few years to registrants within the financial services industry.

The SEC continues to emphasize the primary role and responsibility assumed by management and audit committees in providing meaningful and transparent information to investors. The ever-changing economic and regulatory environment makes the preparation of high-quality reports increasingly important and challenging.

To help you prepare for your annual reporting, we are happy to share this publication, Stay informed | 2015 SEC comment letter trends. In this latest edition of our annual publication we have analyzed SEC staff comment letters issued to registrants across different sub-sectors within the financial services industry, including: Banking and Capital Markets, Insurance, Asset Management, and Real Estate. We have highlighted the areas where registrants have received the majority of comments, both those applicable across the sector, and those specific to a particular financial services sub-sector. We have also provided relevant examples of recent comments along with the applicable accounting and reporting guidance.

Understanding the SEC staff’s recent areas of focus is an important aspect to consider as part of the year-end reporting process. The SEC staff continues to emphasize the importance of providing information to investors that is reliable, meaningful, and transparent, particularly in areas that involve significant judgment. We hope our publication will provide you with helpful insights as you complete the 2015 annual financial reporting cycle.