This report analyzes cyber-related disclosure risks and opportunities based on a review of Securities and Exchange Commission (SEC) comment letters. The SEC’s latest cybersecurity rules issued July 2023 – Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies – generally go into effect for disclosures filed beginning the first quarter of 2024. This…
This paper provides an update on ESG disclosures, more specifically environment and climate-related risks and opportunities. This analysis is based on a review of Securities and Exchange Commission (SEC) Comment Letters that were sent to U.S. public companies from July 2021 to May 2024. Our original December 2022 report covered July 2021 to January 2023…
With segment reporting an ongoing area of concern for the SEC, this report reviews segment reporting comment letter trends. With the expected adoption before the end of calendar year 2023 or Q1 2024 of a significant update to segment reporting requirements by FASB, knowing what the SEC is focusing on can help public companies stay…
The SEC’s Division of Corporate Finance has sent hundreds of comment letters this year questioning the prominence of non-GAAP figures in companies’ earnings releases and other filings in what experts said is an easy gotcha for the staff. …In a review of comment letters sent to Russell 3000 companies between January 2022 and May 2023…
The Securities and Exchange Commission is expected to ask more companies to explain how they calculate performance measures that go beyond U.S. generally accepted accounting principles, a move to gauge whether these metrics could potentially mislead investors. The U.S. securities regulator for years has monitored companies’ use of so-called non-GAAP earnings measures in their financial…
This updated report provides a roadmap for improving environmental, social, and governance (ESG) disclosures related to environment and climate change risks and opportunities. This guidance is based on an analysis of Securities and Exchange Commission (SEC) comment letters that were sent to 10-K and 20-F annual report filers from July 2021 to January 2023. While…
Using data from the MyLogIQ CompanyIQ SEC Comment Letters research platform, MyLogIQ and CFGI analyzed SEC staff comment letters to public companies over the past 18 months. We found that within their ESG-related review, there were 11 climate-related themes that they focused on for 10-K and 20-F annual reports. This joint report identifies the frequency…
Our latest report uses data from our CompanyIQ® SEC Comment Letters database to review climate-related SEC Comment Letters to S&P 500 companies over the last 90 days. 1/3 of S&P 500 Comment Letters in the Last 90 Days Relate to Climate Disclosures One-third of S&P 500 Comment Letters released over the past 90 days (12/4/21-3/4/22)…
With data from the CompanyIQ® SEC EDGAR Comment Letters search tool, this report from LeaseAccelerator is a study of SEC staff comments issued for the new lease standard, Leases (Topic 842) also known as ASC 842, in the first 10 months of 2019. Topic 842 was adopted by most calendar year-end public business entities (PBEs)…
With SEC Comment Letter data from the CompanyIQ® databse, this report looks at ASC 606 compliance. There are nearly 600 codification references of ASC 606 (and related ASC 340-40) in over 430 comments covering a broad range of issues. Just over 180 unique Companies have engaged in a total of 225 conversations (i.e. a few…