Staff document and communicate findings from the review of disclosure filings to supervisors by means of an examination report and draft comments. The tone in 2020 has not changed for both FINRA and SEC when it comes to noncompliance. The Commission received over 10,500 comments via form letters, another 3,200 comments from individuals, and over 900 comments from companies, NGOs, trade associations, and other organizations. EY helps clients create long-term value for all stakeholders. acquisition of a private operating company. We expect these factors to affect the volume of comments next year as well. Senior and middle managers and support offices such as Chief Counsel and Chief Accountant should participate in training. Periodically test the systems to ensure the communications are being captured for review and retention. The Division communicates its comments to the issuer after the filing review to obtain appropriate improvements in disclosure. We made several comparisons (e.g., how well ratings aligned). For instance, the EDGAR system should be easier for the staff to use in uploading documents. Follow along as we demonstrate how to use the site. The participants agreed that, taken as a whole, the Division's comment letter process was achieving its primary objective to improve disclosure to investors. Explore Deloitte University like never before through a cinematic movie trailer and films of popular locations throughout Deloitte University. Office staff read through all of the comments and identified forty-two "resulting issues." Unless noted otherwise, comment letter trend information Issuers who disagree with the views of the Division staff may contact successively higher levels in the Division, including the Director. 2021 edition of this publication because additional 2021 In September 2021, the Securities and Exchange Commission (SEC) provided a sample comment letter that included nine potential climate-related comments the SEC may issue to . These participants described instances where they were embarrassed when an issuer contacted them about a comment they knew nothing about, because the reviewer inserted it without their knowledge. All rights reserved. May be different upon comparisons with the Amendment requests indicate that the required improvements are viewed as material to an investor's decision. 4. An investor attention-based quantitative measure of importance, using EDGAR downloads, also predicts these outcomes. years and may issue comments to such registrants. The letters are limited to the specific facts of the filing in question and do not apply to other filings. Perhaps the most noteworthy finding was that combined management and staff scores indicated that communication of comments was the most important supporting objective and the supporting objective most successfully implemented. On September 22, 2021, in a step that emphasizes the SEC's increased focus on climate change disclosure, the SEC's Division of Corporation Finance ("Corp Fin") issued a sample letter for public companies containing comments illustrative of those that it may issue to companies "regarding their climate-related disclosure or the . Overall Results expect these factors to affect the volume of comments next year as well. annual reporting cycle, they may find it helpful to consider the following SEC The Division should ensure that the new EDGAR system includes improvements in document uploading capabilities and in identifying and tracking issuer's changes to filings, including in the financial statements. Subscribe to receive Roadmap series publications via email. We use cookies to personalize content and to provide you with an improved user experience. Division of Forms 10-K, 10-K/A, 10-Q, and 10-Q/A (which are Areas of focus include: (2) cybersecurity policies and procedures, (4) adherence to fiduciary duty, including adequacy of disclosures, and. Does your firm have policies and procedures in place regarding the filing, updating, and delivery of Form CRS. Each general category contains an average of five sub-elements. To help the SEC meet its responsibilities under the Sarbanes-Oxley Act, Broader SEC priorities often influence comment letter trends. Subscribe to receive a monthly digest of articles exploring regulatory updates, news, trends and best practices in electronic communications capture and archiving. Most frequent comment areas The SEC staff continues to focus on many of the same topics that we highlighted last year. Welcome to Viewpoint, the new platform that replaces Inform. companies. Management and auditors discussed a number of examples of possible objectives in several joint meetings. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. In turn, the Chairman contacted some of the companies for feedback on their experience with the Division's filing review process. However, they also indicated that the training needed to focus more on the work that the staff actually performed. The growing number and complexity of cybersecurity risks facing investment advisers (IAs) have triggered an increased interest in cyber risk management by the SEC, including a planned sweep of more than 50 registered IAs and broker-dealers. In addition, we expect the number of comments to grow next year because of a rise in the number of public companies over the past several years, which is largely attributable to increased transaction activity related to traditional initial public offerings and special-purpose acquisition companies (SPACs) in 2020 and 2021. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. The term "comment letters" may refer either to the letters that individuals and entities submit in response to requests for public comment on SEC rule proposals or concept releases, or to correspondence between SEC staff and SEC filers. To test whether advisors are using unapproved communication channels, I recommend setting up automated keyword searches For example, the Smarsh Professional Archive has the ability to automatically flag emails that contain certain words or phrases likely to warrant review. The Division has already gotten approval for Internet e-mail access. Also, in a 1996 speech, senior Division management indicated that staff comments resulted in increased issuer attention in a number of disclosure areas, including accounting for disposal of assets as discontinued operations, presentation of overly broad geographic segments, and use of valuation allowances. Sharing your preferences is optional, but it will help us personalize your site experience. If your firm and your associated persons agree to provide account monitoring, do you apply the best interest standard to both explicit and implicit hold recommendations? Broader SEC priorities often In addition to cookies that are strictly necessary to operate this website, we use the following types of cookies to improve your experience and our services: Functional cookies to enhance your experience (e.g. The table below summarizes comment letter trends by topic in the 12-month period ended July 31, 2022 (review year 2022 or the current year). 2 For example, the Division contends that as a result of staff comments in FY 1996, forty-one companies were required to restate their income. A SPAC is a newly formed company that raises cash in an Social login not available on Microsoft Edge browser at this time. However, some duplication of comments occurred in categories that included both accounting and legal issues, such as in the Management's Discussion and Analysis (MD&A) section of the filing. and/or revise the labeling of your non-GAAP financial measures in future filings to adequately reflect what is being presented." (SEC Comment Letter to GGP Inc., (March 30, 2017).) Qualitative Analysis We collected two sets of ratings (i.e., actual and importance) for each of the objectives. with large accelerated filers representing 61 percent of the reviews with Managers rated the importance of all of the supporting objectives slightly higher than did the staff. This content is copyright protected. The second type of comment letters, between SEC staff and SEC filers, are contained in the SECs EDGAR database (see How to Search for EDGAR Correspondence). Currently, the two-week timeframe is only provided in unusual cases. window.drift.api.startInteraction({ interactionId: 90922 }); The reversal of this long-term trend may have resulted from (1) the SECs targeted review of climate-change disclosures; (2) recently amended SEC rules related to the description of the business, risk factors, and MD&A; and (3) the use of comments to elicit expanded disclosures related to emerging issues. The objectives selected for evaluation were those that management thought were both important and for which evaluation data would be useful. Communicate Comments Do not delete! This box/component contains code The Division should design and implement formal training for reviewers. Resolve Comments Click here to extend your session to continue reading our licensed content, if not, you will be automatically logged off. Yes, subscribe to the newsletter, and member firms of the PwC network can email me about products, services, insights, and events. Nave Bayesian classification identifies comment letters associated with future restatements and write-downs. A brief statement that precedes the sample comment letter reiterates the view expressed in the SEC's 2010 interpretive guidance that a variety of existing SEC disclosure rules may . Do your firm and your associated persons consider reasonably available alternatives to the recommendation? It is for your own use only - do not redistribute. Composite management and staff ratings for actual achievement of the supporting objectives were reasonably aligned. Assistant Directors (ADs) review the most complex filing issues. In a sign of the significant increased focus on climate change that has taken place under the Biden administration, the Wall Street Journal recently reported that the SEC's Division of Corporation Finance has sent comment letters to "dozens" of companies relating to their climate change disclosures. These keywords or key phrases can be customized to allow the firm to control which words or phrases are flagged and to adjust them as the business changes or new risks emerge. The training is presented by various Division senior staff and managers. Our SEC Reporting Update publication highlights key trends in SEC staff comment letters issued during the year ended 30 June 2020, including comments on accounting and disclosures related to the COVID-19 pandemic, the use of non-GAAP measures, managements discussion and analysis and revenue recognition. We obtained and analyzed information concerning successes, obstacles, recommendations, and effectiveness ratings related to the primary objective and six supporting objectives identified by the Division for the comment letter process. Exceptional organizations are led by a purpose. years to come. However, despite these concerns, participants indicated they were proud to work for the Commission, in particular the Division. business, risk factors, and MD&A, and (3) the use of comments to elicit This sample comment letter follows a recent increase in climate-related . The global business landscape has been changing rapidly, with the The Workshops Participants felt that outstanding staff not only reviewed a lot of filings, but also saw the larger issues in a filing, the impact of their comments on those issues, and knew how to proceed appropriately. She earned her Juris Doctorate from Nova Southeastern University. These factors are crucial to an effective program. The SEC continues to prioritize reviews of larger companies, with large, accelerated filers representing 61% of the reviews with comment letters in the current year even though they represented only 31% of the Forms 10-K filed. The field work was performed between May and October 1997 in accordance with generally accepted government auditing standards. You must consult an attorney for advice regarding your compliance with laws and regulations applicable to your business. The mean (median) number of comment letter rounds is 1.5 (1.0). The Division gave us information on issuers that were contacted by the Chairman within the past year for their views on the filing review process. The regulators will continue to penalize firms and their employees for failing to meet regulatory requirements, including fines and other disciplinary actions. Most of the participants also indicated that they felt a strong sense of responsibility to the investing public and a desire to live up to the Division's, as well as the Commission's, expectations. The SEC continues to prioritize reviews of larger companies, This message will not be visible when page is As registrants start to prepare for the 2022 The SECs office of compliance inspections and examinations (OCIE) released its 2020 exam priorities. comment letters that were closed (i.e., the SEC issued a Sample Letter to Companies Regarding Climate If you require a printed version of this document contact the United States Securities and Exchange Commission, Office of Inspector General, Mail Stop 11-7, 450 Fifth Street N.W., Washington, D.C. 20549 or call (202) 942-4460. comments joining the list. In addition to providing our insights on the nature of the SEC staff comments, we provide sample text from the SEC staffs comments and links to where you can learn more about the accounting and disclosure requirements addressed in each topical area. In the letters, the regulators highlighted technology-related topics while also focusing on existing priorities, reminding firms of the need to adopt comprehensive supervisory processes that will ensure compliance and exam preparedness. Prior to joining Smarsh, Marianna worked for BNY Mellon and Invesco where she was an instrumental member on compliance teams.Marianna has also served as an adjunct professor at New York Career Institute where she taught Law Office Management and Real Estate Law. The Office keyed the anonymous assessment ratings of the workshop participants into Excel spreadsheets for analysis. The rating scale used by the participants ranged from 7 (full implementation) to 1 (not being implemented in a meaningful manner). Consider removing one of your current favorites in order to to add a new one. Appendix B includes the scales used to rate the actual implementation (effectiveness) of the supporting objectives. We also expect the SEC staff to continue monitoring the effects of the COVID-19 pandemic, the Russia-Ukraine war, supply-chain disruptions, labor shortages, inflation, and rising interest rates, as well as other emerging market events, and perhaps focus future comments on accounting and reporting related to these matters. The analysis herein summarizes the The CSA methodology used in the audit consists of four primary tasks: identify management objectives, convene workshops to discuss and rate each objective, evaluate the workshop data, and prepare an audit report. Please enable JavaScript to view the site. guidance related to MD&A and key performance indicators and metrics may A possible approach is to link staff performance evaluations more to the outcomes of filing reviews and impacts on the achievement of the Division's objective (improve disclosure to investors) and depend less on output measures. Technology continues to be a key theme for the regulators. The examination report should also be periodically reviewed and revised as necessary. Participants indicated that they tended to focus more on the activities by which they believed their performance was measured, and less on activities that were important but did not appear to them to affect their performance evaluations. To send a message to . Please see www.pwc.com/structure for further details. Participants felt that the checklist should be reviewed for possible revision. The Division works with the issuer to resolve the comments. Scope And Objectives Transactional filing reviews, such as those related to mergers and acquisitions (M&A), are a priority of the SEC to which it dedicates significant resources. This content is copyright protected. In each episode of our 2022 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC's Division of Corporation Finance. Participants indicated that a more direct link between the training and the filings they actually review would make the training more effective. 2022 Regulatory Roundup: Record-Breaking Penalties Provide a Glimpse Into 2023, Smarsh Advance Recap: Voice The Newest Frontier in Supervision, More Wall Street Sweeps Focus on Off-channel Communications, Our Top 5 Digital Communication Predictions for 2023. Does your firm have policies and procedures to identify and address conflicts of interest? Also, in August 1995, the Chairman organized the Task Force on Disclosure Simplification to review and streamline regulations relating to forms and disclosure requirements. }); COVID-19 pandemic, Russias invasion of Ukraine, supply-chain and labor issues, Copyright 2023 Deloitte Development LLC. 4. Staff Performance Measures, Appendix A - Control Self Assessment Methodology Do your firm and your associated persons apply a best interest standard to recommendations of types of accounts? The applicable policy is dated August 19, 1997. These audit steps are described in further detail in Appendix A. We designed the workshops to be homogeneous with respect to management or professional staff to facilitate subsequent comparisons. Office personnel convened six workshops after obtaining the objectives. In fact, some participants felt they were penalized for their lower production numbers resulting from processing larger, more complex filings than those used in setting the performance standards. Workshop participants agreed that the current process works well in resolving comments. In issuing comments to a company, the staff may request that a company provide additional supplemental information so the staff can better understand the companys disclosure, revise disclosure in a document on file with the SEC, provide additional disclosure in a document on file with the SEC, or provide additional or different disclosure in a future filing with the SEC. The insights and services we provide help to create long-term value for clients, people and society, and to build trust in the capital markets. In other instances, issuers reduced their offering prices or withdrew their offers as a result of the Division's filing review and comment letter process. It also highlights areas the SEC staff may . Approximately 19% of the comment letter conversations include a confidential treatment request from the firm to redact at least a portion of their response letter. The Office generally endorses these recommendations and makes additional recommendations in its report. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. You may withdraw your consent at any time by emailing privacy@smarsh.com. referred to generally as filings). We also expect the SEC staff of the Forms 10-K filed. The results of the review are to be discussed with the staff accountant and examiner, who make the appropriate changes before the comment letter is issued. The term comment letters may refer either to the letters that individuals and entities submit in response to requests for public comment on SEC rule proposals or concept releases, or to correspondence between SEC staff and SEC filers. The Office selected staff to participate in the workshops based on criteria developed by the Office (e.g., must have been on staff at least six months). These materials were downloaded from PwC's Viewpoint (viewpoint.pwc.com) under license. CFGI analyzed 200 comments made by the SEC staff on companies' financial statements and disclosures, made in Management's Discussion & Analysis filed on Form 10-Q and Form 10-K. In these unprecedented times, the SEC continues to provide registrants with proactive guidance as needed and to conduct ongoing reviews and oversight to protect investors. Addressing SEC comment letters can be an arduous process. SEC Reporting, CFGI analyzed over 100 SEC comment letters made available by the SEC between April 1, 2013 and September 30, 2013. Considerations, Including Industry Supervisors measure staff performance through an evaluation process using established performance standards. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. The Institute of Internal Auditors has promoted the concept internationally for the last several years with outstanding results reported. By providing your details and checking the box, you acknowledge you have read the, The following fields are not editable on this screen: First Name, Last Name, Company, and Country or Region. In Our internal subject matter experts and our network of external industry experts are featured with insights into the technology and industry trends that affect your electronic communications compliance initiatives. the SEC staff often issued comments on these topics to request expanded SEC Comment Letter Trends. The printed document may contain agency comments, charts, photographs, appendices, footnotes and page numbers which may not be reproduced in this electronic version. In addition to cookies that are strictly necessary to operate this website, we use the following types of cookies to improve your experience and our services: Functional cookies to enhance your experience (e.g. At Deloitte, our purpose is to make an impact that matters by creating trust and confidence in a more equitable society. On the Radar briefly summarizes emerging issues and trends related to the accounting and financial reporting topics addressed in our Roadmaps. Also, participants have difficulty tracking issuer changes made to electronic filings in response to comments, especially in financial statements. (Bloomberg) Microsoft, which is eliminating 10,000 jobs and trimming some of its hardware lineup, will reduce its HoloLens goggles business as it scales back work on a . to continue monitoring the effects of the COVID-19 pandemic, the Russia-Ukraine customer complaints mentioning such communications? The review also sought to provide management with staff views of the importance of the comment letter process objectives, and to recommend actions to increase the likelihood that their objectives would be achieved. The composite ratings above of actual achievement by the participating managers and staff indicated that, except for program performance measures, the supporting objectives were generally being achieved, although some obstacles were impairing full implementation. We also reviewed reports of 1933 Act registrations filed between October 1, 1996 and June 31, 1997 (1,228 registrations receiving full reviews and 567 registrations receiving a monitor for one or more specific items) to determine the timeliness of the initial filing review comments. result in increased focus and scrutiny from the SEC staff. 7 The Commission is successfully implementing the supporting objective. Data Evaluation These outcomes of staff filing reviews were documented in "quantifiable benefits" memos. You may withdraw your consent to cookies at any time once you have entered the website through a link in the privacy policy, which you can find at the bottom of each page on the website. closed. reviews that are still ongoing or have recently been To make an impact that matters by creating trust and confidence in a more direct link the! Viewpoint, the new platform that replaces Inform Excel spreadsheets for Analysis ADs review... 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( e.g., how well ratings aligned ) participants felt that the checklist should be reviewed possible! And confidence in the capital markets and in economies the world over us personalize your experience... To obtain appropriate improvements in disclosure supporting objective ) number of comment letter rounds is 1.5 ( 1.0 ) they. To help the SEC staff limited to the accounting and financial reporting topics addressed in Roadmaps! Specific facts of the companies for feedback on their experience with the Division filing... And middle managers and support offices such as Chief Counsel and Chief Accountant participate! For both FINRA and SEC when it comes to noncompliance works well in resolving comments and do not....
