Technology, media and telecommunications - 2017 SEC comment letter trends

SEC comment letter trends Dec 07, 2017

Our publication provides a comprehensive analysis of recent SEC staff comments around disclosures to assist you in understanding the key trends relevant to companies in the technology, media and telecommunications sector.

Overview

We are pleased to provide the 2017 edition of our annual publication, 2017 SEC comment letter and disclosure trends, intended to provide you with an understanding of the SEC staff’s recent areas of focus specific to registrants in the Technology, Media and Telecommunications (TMT) sector. In our effort to provide you with in-depth information on industry-defining areas of scrutiny, we have also analyzed the most recent year-end filings of 160 registrants across the industry’s subsectors and have benchmarked selected disclosures, including those related to non-GAAP measures and segment reporting.

During 2017, the SEC staff used public forums to express their focus on registrants’ disclosures of the status of their implementation of the FASB’s new standards related to revenue, leases, the accounting for credit losses and the expected impact these standards may have on financial reporting for each registrant upon adoption. We expect this to remain a focus area. But while non-GAAP disclosures were a hot topic last year, recent comments from the SEC staff have noted progress in this area since the May 2016 release of the SEC staff’s Compliance and Disclosure Interpretations. As a result, we expect the volume of comments in this area to decline. That said, the SEC staff will continue to monitor the use of non-GAAP measures and will comment when registrants giving them inappropriate prominence.

The sector has continued to evolve at a mind-bending pace. From advancements in machine learning and robotics, 3D video, virtual reality, artificial intelligence and autonomous vehicle technologies, we have continued to watch the lines between industries blur as many of these technologies have applications across industries. In the midst of all the innovation, the sector has experienced a high volume of merger and acquisition activity and financing transactions, including an increasing number of companies either initiating or otherwise exploring the possibility of an IPO. Additionally, registrants have been gearing up for the looming implementation of the new revenue recognition standard. With all of this change, the preparation of high-quality financial reporting and related disclosures continues to be a challenge. We hope this publication helps you as you navigate the year-end reporting cycle.

To have a deeper discussion, please contact:

Kevin Healy

US TMT Industry Assurance Leader

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Valerie Wieman
Partner, National Professional Services Group
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