Industrial Products: 2016 SEC comment letter trends

SEC comment letter trends Nov 08, 2016

This edition provides an analysis of SEC staff comments to help executives understand key trends that are relevant to companies in the industrial products sector.


Over the past year, companies in the industrial products sector have been challenged by uncertainty and change, such as fluctuations in exchange rates and commodity prices, and the implications of Britain’s departure from the European Union. Change has also been introduced by ongoing regulatory developments in financial reporting, such as the SEC’s May 2016 publication of interpretations regarding use of non-GAAP financial measures. High-quality financial reporting and transparency in communicating with investors and other stakeholders remains key as companies implement strategies to address these matters.

In this edition of our annual publication, we have analyzed SEC staff comment letters published between July 1, 2015 and June 30, 2016 for registrants across the industrial products sector. We have highlighted the topical areas where the industry has received the most comments and provided sample examples to aid you in ensuring that your disclosures are robust and consistent with relevant accounting and reporting guidance. We have also included an update and discussion of the SEC’s on-going disclosure effectiveness project and an overview of the SEC comment letter process and best practices.

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Valerie Wieman
Partner, National Professional Services Group

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