A roadmap to SEC comment letter considerations, including industry insights (2018) 

This publication contains extracts of frequently issued SEC staff comments, analysis of those extracts, and links to resources that are relevant to SEC filers. The 2018 edition features (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, 2018; 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.

We are frequently asked to provide our perspective on the topics the SEC staff focuses on in its comment letters to registrants. Over the past year, the staff has continued to address most topics discussed in the 2017 edition of this publication and, in some cases, shifted its focus to new areas, including the adoption by calendar-year-end public business entities of ASC 606, Revenue From Contracts With Customers, and the impact of the Tax Cuts and Jobs Act enacted on December 22, 2017.

The 2018 edition of A Roadmap to SEC Comment Letter Considerations, Including Industry Insights offers perspective on such comment letter trends. In addition to extracts of letters and links to relevant related resources, it contains analysis of staff comments to help registrants understand trends and improve their financial statements and disclosures. You will also find an update on some of the SEC’s strategic priorities as well as a summary of comment letter trends related to the top 10 topics of frequent comment and other various comment letter statistics. The 2018 edition also includes the following appendixes: (1) Appendix A, which gives a glimpse into the SEC staff’s review and comment letter process; (2) Appendix B, which discusses best practices for working with the SEC staff; (3) Appendix C, which provides helpful tips on searching the SEC’s EDGAR database for comment letters; (4) Appendix D, which highlights the changes made in this year’s publication; (5) Appendix E, which lists the titles of standards and other literature referred to in this publication; and (6) Appendix F, which defines the abbreviations we used.

The 2018 edition captures developments on relevant financial reporting topics through the date of publication. 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 AICPA Conference is a prime example. 


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The Roadmap Series contains periodic collections of our accounting guidance on selected topics of broad interest to the financial reporting community.

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