Industrial Products sector 2012 SEC comment letter trends

December 2012
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Industrial Products sector 2012 SEC comment letter trends

At a glance

PwC has issued a summary document of comment letter trends and considerations for year-end financial reporting for industrial products and services companies. Areas reviewed include management discussion and analysis, goodwill impairment, revenue recognition, and much more.

Stay informed

PwC discusses key comment letter trends and considerations for the drafting of 2012 year-end financial reporting based on comment letters published by the SEC from January 1, 2011, to September 30, 2012, as they pertain to companies in Aerospace & Defense, Business & Professional Services, Chemicals, Engineering & Construction, Forestry, Paper & Packaging, Industrial Manufacturing, Metals, and Transportation & Logistics.

We have highlighted the areas that received the most comments from the SEC and provided relevant examples of recent comments to aid preparers in ensuring that their disclosures are robust and consistent with relevant accounting and reporting guidance.

Hot topics discussed in this paper include:

  • Management’s discussion and analysis
  • Loss contingencies
  • Debt covenants
  • Goodwill impairment
  • Income tax provision
  • Impairment of long-lived assets
  • Disclosure of operations in locations identified as state sponsors of terrorism
  • Cash and cash equivalents held by foreign subsidiaries
  • Non-GAAP measures
  • Revenue recognition: percentage of completion