Preface
We are pleased to present the 2024 edition of
SEC Comment Letter Considerations, Including Industry Insights, which offers our
perspectives on topics highlighted in the SEC1 staff’s comment letters to registrants. In addition to extracts of letters and links
to relevant related resources, this Roadmap contains analysis of staff comments to help
registrants understand trends and improve their financial statements and disclosures. You
will also find (1) an update on some of the SEC’s strategic priorities, (2) a summary of
comment letter trends related to the top 10 topics of frequent comment, and (3) analysis of
other comment letter statistics.
Over the past three years, the SEC has
actively engaged in rulemaking that is expected to have a significant impact on registrants.
For example, it has issued final rules related to cybersecurity disclosures,2
climate-related disclosures, special-purpose acquisition companies (SPACs), and “clawback”
policies. The 2024 edition of this Roadmap captures developments on
relevant financial reporting topics through November 1, 2024. The SEC and its staff will
continue to provide registrants with information that is pertinent to their filings by means
of rulemaking and written interpretive guidance as well as speeches delivered at various
forums, of which the annual AICPA & CIMA Conference on Current SEC and PCAOB
Developments (the “AICPA Conference”)3 is a prime example.
Regarding procedural matters, Appendix A gives a glimpse into the SEC
staff’s review and comment letter process, Appendix B discusses best practices for working with the SEC staff, and
Appendix C provides helpful
tips for searching the SEC’s EDGAR database for comment letters.
For a summary of updates to this Roadmap since
publication of the 2023 edition, see Appendix F.
Be sure to check out On the Radar (also available as a stand-alone publication), which briefly summarizes
emerging issues and trends related to the accounting and financial reporting
topics addressed in the Roadmap.
Note that the Roadmap is not a substitute for
the exercise of professional judgment, which is often essential to complying with the
applicable accounting and disclosure requirements. It is also not a substitute for
consulting with Deloitte professionals on complex transactions and SEC reporting
matters.
We hope you find this Roadmap to be a
useful resource as you prepare your annual reports and plan for the upcoming year. We
encourage you to consider materiality, relevance, and redundancy as you assess whether to
provide additional disclosures or enhance existing ones.
Footnotes
1
For a list of abbreviations used in this publication, see Appendix E.
2
For a list of the titles of standards and other literature referred to
in this publication, see Appendix
D.
3
“CIMA” was added to the name of the conference in 2021 to reflect the
new association between the AICPA and London-based Chartered Institute of Management
Accountants.