Pensions and other postretirement benefits: 2013 SEC comment letter trends

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11/24/2013 by Human resource services
Pensions and other postretirement benefits: 2013 SEC comment letter trends

At a glance

This PwC publication includes an analysis of comments made by the SEC staff to registrants published on the SEC’s website between January 1, 2013 and September 15, 2013 related to pensions and postretirement benefits other than pensions (OPEB). There were 37 companies that received one or more comments related to pensions and OPEB during that period, for a total of 78 comments.

Highlights of findings regarding these comment letters:

  • 90% of the comments received related to 10-K and 10-K/A filings
  • When evaluated by section of the filing, 61% of the total number of comments received related to Management’s Discussion & Analysis of Financial Condition and Results of Operations (MD&A)
  • When evaluated by topical area, 37% of the comments received related to assumptions, 21% related to non-GAAP financial measures/adjustments and 12% related to liquidity and cash flows, with the remainder across a variety of topics
  • When evaluated by industry, 57% of the comments received related to companies in the industrial products industry and 13% related to the retail industry, with the remainder across a variety of sectors. This may not be too surprising, considering that companies that continue to offer traditional pension plans tend to be more established companies, such as those in the industrial products sector.