Power & utilities: 2017 SEC comment letter trends

SEC comment letter trends Nov 27, 2017

This edition provides an analysis of SEC staff comments to help executives understand key trends that are relevant to companies in the power and utility industry.


Over the past year, companies in our sector have been challenged by uncertainty and change, such as fluctuations in commodity prices, acquisition and divestiture activity, regulatory developments, technological advancements, and uncertainty regarding the potential impact of tax reform. Change has also been introduced by ongoing 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 power and utility industry. 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

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