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deloitte comment letter trends ?

### Comment Letter Trends by the SEC: Deloitte’s Insights Offer a Roadmap for Registrants

The recent publication by Deloitte, titled « A Roadmap to SEC Comment Letter Considerations, Including Industry Insights, » is an indispensable guide for understanding current trends and practices in SEC comment letters. Deloitte provides an in-depth analysis of how companies have been scrutinized and reported on by the SEC, offering valuable perspectives on a variety of issues including the specifics of comment letter trends and the impacts of the global pandemic on financial disclosures.

#### An Overview of SEC Comment Letters

When a company files a registration statement, periodic report, or proxy statement, the SEC staff might issue comments that require management and auditors to address specific concerns. Comment letters are designed to ensure financial reporting compliance and adherence to principles of fair and comprehensive disclosure. Deloitte compiles and analyzes these letters, highlighting trends and providing an invaluable perspective for SEC registrants.

#### Highlights from Deloitte’s 2020 Edition on SEC Comment Letters

The 2020 edition of Deloitte’s « A Roadmap to SEC Comment Letter Considerations » points out significant trends in how the SEC is reviewing disclosure and financial reporting in the wake of the global pandemic. Notably, Management’s Discussion and Analysis (MD&A) and risk factor disclosures have emerged as primary areas of focus. This heightened scrutiny in MD&A is particularly critical as companies are expected to address the uncertainties and challenges brought on by the pandemic, thereby ensuring transparency in their financial disclosures.

#### A Deeper Dive into the Trends

One of the striking features of Deloitte’s roadmap is its breakdown of the top 10 topics of frequent comment in the 12 months ending July 31, 2020. The report compiles a comprehensive summary that supports registrants in understanding and anticipating SEC staff’s priorities, serving as an essential tool for companies navigating their SEC reporting obligations.

Furthermore, the publication not only extracts comment excerpts from the SEC but also provides in-depth analysis and links to relevant resources. Deloitte highlights the importance of specific accounting standards, like revenue recognition and the application of new or revised accounting principles, as these areas have seen increased scrutiny from the SEC staff.

#### Practical Guidance for Companies

Deloitte’s report is more than a compilation of findings; it is a roadmap filled with practical examples and a wealth of insights designed to help registrants improve their SEC filings. The detailed appendices offer an inside look into the SEC review and comment process, while also supplying industry-specific guidance.

For companies trying to prepare for SEC reviews or to fine-tune their financial disclosures, Deloitte’s materials can provide useful tips and practical advice on how to handle these aspects effectively. The insight also helps in understanding what the SEC staff values in filings, such as clear and thorough explanations of financial changes and the rationale behind financial figures.

#### Additional Insights From Industry Experts

To complement Deloitte’s contribution, other firms like PwC and EY have also published insights on SEC comment letter trends and financial reporting trends. These analyses, while not entirely exhaustive, provide a broad overview of recent trends and the evolving priorities of the SEC staff.

EY, for its part, provided a report detailed in the SEC Reporting Update, which analyzed trends in SEC staff comment letters issued during the fiscal year ending June 30, 2020. Among the issues identified are common topics such as the non-GAAP financial measures, revenue recognition, and the impacts of the pandemic on reporting practices. EY’s report also offers guidance for registrants on best practices and gives a preview of the SEC’s likely focus for the following period.

#### Conclusion

Deloitte’s work on SEC comment letter trends is a vital asset for anyone involved in SEC reporting, as it provides clear and actionable insights into the workings of the SEC. By understanding the recent emphasis on areas such as MD&A and risk factors, companies can more effectively prepare their filings and ensure they meet the evolving standards for transparency and disclosure, especially in challenging times like a pandemic.

Registering companies, preparers, and auditors alike can benefit significantly from studying this material and applying these practices in their SEC filings, knowing they are following the leading recommendations from one of the biggest names in professional services. By tapping into Deloitte’s extensive analysis and expert insights, they not only meet the necessary compliance standards but go above and beyond in providing transparent and clear communication to their stakeholders.