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SEC Comment Letter Considerations, Including Industry Insights (2019)

A Roadmap to SEC Comment Letter Considerations, Including Industry Insights (2019)

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  • Download the PDF version (available without subscription; not updated after issuance).
  • View the active version (subscription required; updated as warranted). For subscribers, links to substantive changes made to the Roadmap since its issuance, if any, will be provided below.
This publication contains extracts of frequently issued SEC staff comments, analysis of those extracts, and links to resources that are relevant to SEC filers. Other features include (1) an update on the SEC’s priorities; (2) a summary of comment letter trends related to the top 10 topics of frequent comment in the 12-month period ended July 31, 2019; and (3) topics of focus related to disclosures associated with financial statement accounting, SEC reporting, initial public offerings, foreign private issuers, and industry-specific matters. Appendix F of the Roadmap summarizes the changes made in the 2019 edition.