SEC comment letters – What’s trending in 2024

PwC's accounting podcast

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We are kicking off our miniseries on 2024 SEC staff comment letters, helping to inform you on the latest trends as you gear up for year end. In this episode we share an overview of the 2024 comment letter trends, as well as insights into the SEC staff’s key priorities.
In this episode, we discuss:

• 1:56 – An overview of the SEC comment letter process
• 14:19 – 2024 SEC comment letter themes
• 15:31 – Key SEC staff focus areas related to management’s discussion and analysis
• 18:59 – Key SEC staff focus areas related to non-GAAP measures
• 21:37 – Other reminders and areas that preparers should focus on moving into year end

For more information, see our full analysis of SEC comment letter trends. Additionally, follow this podcast on your favorite podcast app for more episodes.
Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.
Heather Horn is the PwC National Office Sustainability and Thought Leader, responsible for developing our communications strategy and conveying firm positions on accounting, financial reporting, and sustainability matters. In addition, she is part of PwC’s global sustainability leadership team, developing interpretive guidance and consulting with companies as they transition from voluntary to mandatory sustainability reporting. She is also the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series.
Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [e-mail].

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1. SEC comment letters – What’s trending in 2024 (00:00:00)

2. An overview of the SEC comment letter process (00:01:56)

3. 2024 SEC comment letter themes (00:14:19)

4. Key SEC staff focus areas related to management’s discussion and analysis (00:15:31)

5. Key SEC staff focus areas related to non-GAAP measures (00:18:59)

6. Other reminders and areas that preparers should focus on moving into year end (00:21:37)