CAQ Releases Highlights of March 2021 Joint Meeting With the SEC Staff

The Center for Audit Quality (CAQ) has published highlights of the March 24, 2021, CAQ SEC Regulations Committee joint meeting with the SEC staff.

Topics discussed at the meeting included:

• Presentation of pro forma earnings per share in IPO registration statements.
• Implementation questions regarding final amendments to requirements for disclosures about acquired and disposed-of businesses.
• Financial statements used to determine significance for an acquisition shortly after year-end.
• Staff observations regarding waivers related to significant acquisitions.
• Implementation questions regarding final amendments to MD&A, selected financial data, and supplementary financial information.
• Staff observations on requirements for disclosures about critical audit matters in certain scenarios involving emerging growth companies.
• Financial statement requirements in an Form S-4 registration statement or merger proxy statement for a nonreporting target merging with a public operating company, shell company, or special-purpose acquisition company in a reverse merger.
• Staff reminder that draft or initial registration statements must be complete when submitted or filed.