2020 SEC comment letter trends

11/24/20

PwC partners Heather Horn, Ryan Spencer, and Kyle Moffatt discuss their perspectives on the SEC comment letters issued in the 2020 review cycle.

To help you prepare your year-end financial statements, listen to PwC partners Heather Horn, Ryan Spencer, and Kyle Moffatt give their observations from SEC comment letters made public in 2020. In addition to discussing top areas of interest—including COVID-19, revenue recognition, non-GAAP, MD&A, and segment reporting—they also provide a few best practices for responding to SEC comments.

Topics include:

0:46 - Overview. As former Chief Accountant and Disclosure Program Director in the SEC’s Division of CorpFin, Kyle shares his unique perspective on the SEC’s filing review program and all the parties involved.
10:27 - Overall trends. Ryan shares his observations with respect to the overall trends in SEC comment letters in 2020, including:
- 13:16 - MD&A
- 17:07 - COVID-19
- 18:46 - Non-GAAP
- 25:37 - Revenue recognition
- 27:29 - Segment reporting
31:02 - Best practices. Before wrapping up, Ryan and Kyle provide a handful of best practices on the most effective way to respond to comment letters.

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About our guests

Ryan Spencer is a Partner at PwC's National Office specializing in SEC financial reporting. He has over 20 years of experience serving clients and is a frequent contributor to PwC’s publications and communications.

Kyle Moffatt is a partner in PwC's National Office where he consults with engagement teams and audit clients on SEC reporting matters. He joined PwC in April 2020 after spending almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

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.