CAQ Publishes Highlights of IPTF’s May and November 2021 Meetings With SEC Staff

“Updating annual financial statements for retrospective accounting that is first reflected in interim financial statements or interim financial information.”

“IFRS 1 adoption at the beginning of the one-year only financial statements in a confidential IPO submission” (draft registration statement [DRS]).

“Missing comparative for interim period when interim financial information is voluntary in a confidential IPO submission (DRS).”

“Risk factor disclosure in an existing registration statement and in a new registration statement.”

“FPI Transactions involving SPACs.”

“Considerations when a registrant provides interim financial information in a registration statement solely to comply with Form 20-F Item 8.A.5.”

“The requirements for disclosure of changes in a registrant’s certifying accountant in an IPO or SPAC merger where only a statutory audit has historically been performed (perhaps under a different basis of accounting and/or different auditing standards were used).”

“SEC staff observations re comment letters on China-based registrants.”