2019 SEC comment letter trends

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Hear about recent trends in SEC comment letters—and, best practices on how to respond if you get one.

To help you prepare your year-end financial statements, listen to PwC partners, Heather Horn and Martin Thiselton-Dyer, give their observations from SEC comment letters made public in 2019. In addition to discussing top areas of interest—including revenue recognition, leases, and non-GAAP—they also provide a few best practices when responding to SEC comments. Topics include:

  • 0:54 - Overview. Martin gives a brief refresher on the SEC comment letter process.

  • 6:40 - Overall trends. Martin shares his observations with respect to the overall trends in SEC comment letters in 2019.

  • 9:34 - Recurring themes. Some things never change. We discuss the remarkable consistency in the focus areas over time, including revenue recognition, non-GAAP measures, and MD&A.

  • 18:16 - New accounting. Martin and Heather discuss observations from SEC comments on new accounting standards.

  • 23:56 - Best practices. Before wrapping up, Martin provides a handful of best practices on the most effective way to respond to comment letters.

About our guest

Martin Thiselton-Dyer is a partner in the SEC Services group of PwC’s National Office. Martin serves companies from around the world and in a variety of industries in connection with their private and public US capital raising, and advises on accounting and disclosure matters related to filings made with the SEC.

About our host

Heather Horn is PwC's National office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series, as well as periodic webcasts for the power and utilities industry. With over 25 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Contact us

Heather Horn

Heather Horn

US Strategic Thought Leader, National Professional Services Group, PwC US

David Schmid

David Schmid

International Accounting Leader, National Professional Services Group, PwC US

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