Industrial products: 2017 SEC Comment letter trends

SEC comment letter trends , PwC US Nov 14, 2017

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Take a closer look at the latest SEC comment letters and trends to prepare your end of year financial reports and high quality annual reports.


Over the past year, companies in our sector have been challenged by uncertainty and change, such as fluctuations in exchange rates and commodity prices, acquisition and divestiture activity, technological advancements, including digitization, and uncertainty regarding the potential impact of tax reform. Change has also been introduced by ongoing regulatory developments in financial reporting, such as the SEC staff’s continued focus on the use of and disclosures surrounding non-GAAP financial measures and registrants’ disclosures of the status of implementation of the FASB’s new standards related to revenue and leases. High-quality financial reporting and transparency in communicating with investors and other stakeholders remains key as companies implement strategies to address these matters.

In this edition of our annual publication, we have analyzed SEC staff comment letters published between July 1, 2016 and June 30, 2017 for registrants across the industrial products sector. We have highlighted the topical areas receiving the most focus and provided sample comments that may help you ensure your disclosures are robust and consistent with relevant accounting and reporting guidance and SEC staff expectations. We have also included an overview of the SEC comment letter process and best practices.

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Valerie Wieman
Partner, National Professional Services Group, PwC US

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