SEC Comment Letter Considerations, Including Industry Insights
A Roadmap to SEC Comment Letter Considerations, Including Industry Insights
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substantive changes made to the Roadmap since its
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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.
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