Based on the number of SEC comment letters publicly published, the overall volume has been steadily decreasing for the last nine years. We looked at the most common issues raised in an SEC comment letter; the table below shows 10 of the top issues discussed in these letters over the past three years. It is important to note that, in many cases, more than one issue is mentioned.

numeric table listing common issues with SEC comment letters and the numbers of reviews with a comment on respective topic

The major topics in 2018 were similar to what we have seen in 2016 and 2017, with MD&A, the use of non-GAAP measures and fair value comments at the top of the list. There are, however, some new emerging trends SEC filers should consider:


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The Securities and Exchange Commission is extending the compliance date for the recently adopted amendments to Rule 606 of Regulation National Market System (“Regulation NMS”) under the Securities Exchange Act of 1934 (“Exchange Act”), which require additional disclosures by broker-dealers to customers concerning the handling of customer orders.

Business men and women meeting in background behind computer and data sheets.


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Miriam Rouziek, an Audit Manager and one of the faces of the PKF Texas SEC team. Miriam, welcome back to The Playbook.

Miriam: Thanks for having me, Jen.

Jen: So, we’ve been talking a little bit about PCAOB, which is the Public Company Accounting Oversight Board, and we’ve been talking about some changes that they’ve had. But what inspection trends are you seeing?


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back once again with Miriam Rouziek, one of our Audit Managers and one of the faces of PKF Texas’s SEC team. Miriam, welcome back to The Playbook.

Miriam: Thanks for having me, Jen.

Jen: In previous episodes we’ve talked a little bit about the PCAOB, which stands for Public Company Accounting Oversight Board, which I know was founded after the whole Enron thing. What changes do they have coming for 2019 – 2020?


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Miriam Rouziek, an Audit Manager and one of the faces of PKF Texas’s SEC team. Miriam, welcome back to the Playbook.

Miriam: Thank you for having me, Jen.

Jen: So, tell us what’s coming down the pipe with the SEC? Are they doing any updates this year in 2019?

Miriam: Yeah. The SEC is really going to start focusing on some different things here in 2019.


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Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, this week’s guest host, and I’m here today with Ryan Istre, an audit director and a member of the PKF Texas SEC team. Ryan, welcome back to the Playbook.

Ryan: Thanks for having me here, Jen.

Jen: So, I know there’s new revenue recognition rules coming. What are the SEC’s views on this for registrants?

Ryan: That’s a very good question, Jen. The new revenue recognition rules – or ASC 606 – are going to be effective for most registrants beginning January 1st of 2018.


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