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Audit Committee Evolution – Some Next Steps

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Over the last two months we have done a series of posts about the evolution of the role of the audit committee and related disclosures:

Part One – Overview and Some History seciblog.pli.edu/?p=447
Part Two – Independence Oversight seciblog.pli.edu/?p=450
Part Three – Audit Fee Disclosures –A Few Common Problem Areas in This Independence Disclosure  seciblog.pli.edu/?p=456
Part Four – The SEC’s Concept Release seciblog.pli.edu/?p=462
Part Five – Voluntary Disclosures in the News   seciblog.pli.edu/?p=486

 
In this last post in the series we discuss two resources for audit committees:

  1. The PCAOB’s outreach to audit committees, and
  2. Our PLI programs for audit committee members

 

PCAOB Outreach to Audit Committees

Recognizing the importance of audit committee oversight of the audit process, the PCAOB has included information for audit committees on their webpage to help audit committees in their oversight role. They have also begun a regular newsletter, “Audit Committee Dialogue”. The newsletter is on the same webpage, along with a number of other resources.
pcaobus.org/Information/Pages/AuditCommitteeMembers.aspx

 

PLI Programs for Audit Committee Members

And, lastly, here are some of our PLI programs that will help audit committee members and other directors build and maintain the knowledge and expertise to appropriately fulfill their responsibilities. Most of these programs are available via web archives, webcast and live attendance. You can learn more about all our programs at www.pli.edu.

Audit Committees and Financial Reporting 2016: Recent Developments and Current Issues
www.pli.edu/Content/Seminar/Audit_Committees_and_Financial_Reporting/_/N-4kZ1z11i36?fromsearch=false&ID=259781

Audit Committees and Financial Reporting 2015: Recent Developments and Current Issues www.pli.edu/Content/OnDemand/Audit_Committees_and_Financial_Reporting/_/N-4nZ1z129aq?ID=221250

Corporate Governance — A Master Class 2016

www.pli.edu/Content/Seminar/Corporate_Governance_A_Master_Class_2016/_/N-4kZ1z11ij4?fromsearch=false&ID=259397

 
Directors’ Institute on Corporate Governance (Thirteenth Annual)www.pli.edu/Content/OnDemand/Directors_Institute_on_Corporate_Governance/_/N-4nZ1z129if?fromsearch=false&ID=221435

 

As always, your thoughts and comments are welcome!

The New Revenue Recognition Standard – When to Start Implementation?

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Implementing the new revenue recognition standard is a major challenge that many of us face between now and January 1, 2018 (or whatever fiscal year you have that begins after that date of course.) Many professionals are happy to be close to retirement at this point in time!

With the magnitude of the change in this new standard, including the significantly expanded disclosures which apply to everyone, when is the appropriate time to begin implementation efforts? This is a very complex question. There are still some moving parts as the FASB and IASB continue to make changes to the final standard. The new standard can have varying impacts across companies depending on such issues as complexity of contracts, how product is delivered, do you have software licenses, and principal versus agent issues, to name a few. While the TRG has addressed many issues, there are only a few left to be resolved. While this may seem to be a good sign, the SEC staff has stated concerns that there are not more issues being raised, attributing the low number as a sign that perhaps implementation initiatives are not far enough along or are not being elevated to the TRG (see the September 17th speech by Wesley Bricker, Deputy Chief Accountant in the SEC’s Office of Chief Accountant at: http://www.sec.gov/news/speech/wesley-bricker-remarks-bloomberg-bna-conf-revenue-recognition.html)

There is much discussion about when to begin implementation discussions. To date there has not been much hard data about what companies are actually doing. The Financial Executives Research Foundation (FERF), which is an affiliate of FEI, and PwC have teamed up to survey companies about this issue.

As nearly as we can tell, this is the first really good data about where companies are in the implementation process. You can find the study at:

www.pwc.com/us/revrecsurvey

The survey deals with a number of issues surrounding the impact and implementation of the new standard. It is a good read, and worth spending some time digesting. Here are a couple of things to ponder while you read.

  1. Do you have a reasonable understanding of how the new standard will affect your accounting and disclosure?
  2. What resources will you need in this effort?
  3. What level of organizational involvement across functional areas will be necessary (e.g., sales, legal, etc.)?

As always, your comments and thoughts are welcome!

Comment of the Week – The Mystery of Market Risk Disclosures

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Market Risk Disclosures are one area that many participants in our workshops seem to shy away from. This Item is one of the less well understood disclosures in Forms 10-K and 10-Q. The mechanics of writing the disclosure are, well, at best, mysterious.

With all the volatility in exchange rates, oil prices and other markets in the current environment these disclosures will likely become more important for many companies this year end. Because of this, we thought “going to go back to the basics” of this disclosure would be helpful in many companies’ year end process. So, this post includes a review of the objective of the disclosure and some tips to navigate the requirements in S-K Item 305 as you prepare the disclosure.

Since this is a comment of the week post, there are also some comments at the end of the post. If you are already comfortable with what market risk disclosures are about and how they work, you can skip to the end!

Objective of the Disclosure

To prepare these disclosures well it is crucial to understand their objective, what they are supposed to tell a reader. To understand this objective the first step is to understand what kind of risk the term “Market Risk” means. Market risk is a term that can be interpreted in a number of different ways ranging from the market for a particular product to market driven rates such as interest rates or commodity prices.

Deep in the body of Regulation S-K – Item 305, likely one of the most challenging reads in all of Regulation S-K, you find these instructions:

Instructions to paragraph 305(b): 1. For purposes of disclosure under paragraph 305(b), primary market risk exposures means:

  1. The following categories of market risk: interest rate risk, foreign currency exchange rate risk, commodity price risk, and other relevant market rate or price risks (e.g., equity price risk); and
  2. Within each of these categories, the particular markets that present the primary risk of loss to the registrant. For example, if a registrant has a material exposure to foreign currency exchange rate risk and, within this category of market risk, is most vulnerable to changes in dollar/yen, dollar/pound, and dollar/peso exchange rates, the registrant should disclose those exposures. Similarly, if a registrant has a material exposure to interest rate risk and, within this category of market risk, is most vulnerable to changes in short-term U.S. prime interest rates, it should disclose the existence of that exposure.

To paraphrase, these disclosures are not about the “market” for a product like computers or smartphones. They are about the risks a company faces from market driven prices like interest rates or commodity prices. So, while the market for smart phones could affect a company, the Market Risk Disclosures are about issues like how a change in interest rates could affect a company if the company has significant investments or borrowings.

And that brings us to the next step in understanding the objective of these disclosures. Once we know what sort of market risk we need to describe, what should we say about it?

In S-K Item 305(a)(1)(ii)(A) you will find this language:

“sensitivity analysis disclosure that expresses the potential loss in future earnings, fair values, or cash flows of market risk sensitive instruments resulting from one or more selected hypothetical changes in interest rates”

In other words, this disclosure is designed to help a reader assess how much a change in a market driven price, such as an interest rate or a commodity price, would affect the business.

Conceptually what this disclosure is about is fairly easy to understand. However, the application of S-K Item 305 is complex. It requires both qualitative and quantitative information   Our review here is fairly brief. S-K Item 305 has a maze of detailed rules. If you will be drafting or reviewing the disclosure you should refer to the actual S-K language. Also, the comments below illustrate several of the complexities in this rule.

Qualitative Disclosures

The logical place to start drafting is with qualitative disclosures. Knowing what a company’s market risks are is necessary before quantitative information will make sense to a reader. Unfortunately, in Item 305, the qualitative disclosures are sort of hard to find, as they are not the first thing listed. You can find them in paragraph (b), which says:

(b) Qualitative information about market risk.

(1) To the extent material, describe:

(i) The registrant’s primary market risk exposures;

(ii) How those exposures are managed. Such descriptions shall include, but not be limited to, a discussion of the objectives, general strategies, and instruments, if any, used to manage those exposures; and

(iii) Changes in either the registrant’s primary market risk exposures or how those exposures are managed, when compared to what was in effect during the most recently completed fiscal year and what is known or expected to be in effect in future reporting periods.

This qualitative information is really pretty simple; say what market driven prices such as interest rates, exchange rates, commodity prices or other types of prices affect the company; talk about how you manage them; and tell if they have changed. Note that the rules do not require that a company manage these risks, so if you don’t manage them, you should disclose that, along with the other information in (b) (10) above.  (Here is one place to review Item 305 in detail, as this disclosure needs to be broken down in pretty specific ways by type and source of risk.)

Quantitative Disclosures

The second part of this disclosure is quantitative, and is designed to help a reader understand how much a hypothetical change in market prices or rates could affect the business. Again, this is a very detailed requirement, but in essence starts with a choice among three alternatives:

Tabular Disclosure

S-K Item 305(a)(1)(i)(A)(1) describes a tabular presentation of information related to market risk sensitive instruments. This information includes fair values of the market risk sensitive instruments and contract terms sufficient to determine future cash flows from those instruments, categorized by expected maturity dates. In essence you are providing a reader with the input they could use to build a spreadsheet, make a price change assumption, and see how much the price change would affect the company’s income, cash flows or fair values.

Sensitivity Analysis

S-K Item 305(a)(1)(ii)(A) describes a sensitivity analysis disclosure that expresses the potential loss in future earnings, fair values, or cash flows of market risk sensitive instruments resulting from one or more selected hypothetical changes in interest rates, foreign currency exchange rates, commodity prices, and other relevant market rates or prices over a selected period of time. In essence, in this disclosure you build your own spreadsheet and assume a hypothetical change in rates or prices and compute the impact.

Value at Risk Analysis

S-K Item 305(a)(1) (iii)(A) describes value at risk disclosures that express the potential loss in future earnings, fair values, or cash flows of market risk sensitive instruments over a selected period of time, with a selected likelihood of occurrence, from changes in interest rates, foreign currency exchange rates, commodity prices, and other relevant market rates or prices. This is actually a complex econometric modeling process, and we won’t discuss it any further in this post. If your treasury or risk management group already uses this technique to assess risk it may well be a good disclosure option.

Again, this is very complex disclosure. You can choose one of the three alternatives for different risks, however you must disclose the most significant impact based on future earnings, fair values, and cash flows. Therefore, you must calculate the impact of a price change on income, cash flows and fair value to determine which has the greatest change, and thus is disclosed. Of course, If future earnings had the greatest impact last year, and this year the greatest impact is in fair value, then you would need to recast the prior year. These are only some of the judgments necessary to prepare this disclosure.
One last note, as you can see this disclosure is very forward looking, and is another reason the 1995 Private Securities Litigation Reform Act safe harbors are so important!
Example Comments

Last but not least, as this is a comment of the week post, here are some comments. Notice the focus on simple compliance with the S-K Item 305 disclosure requirements!

Foreign Currency Fluctuations, page 37

  1. We note from your disclosure on page 28 and in Note 26 that a substantial portion of your cash is held by foreign subsidiaries and 46% of your net sales to unaffiliated customers for fiscal 2014 were attributed to your foreign subsidiaries, respectively. We believe your market risk disclosures should be enhanced to provide a more robust discussion of the effects of foreign currency risk on your results of operations and financial condition. Additionally, your discussion of this market risk does not appear to comply with the guidance outlined in Item 305 of Regulation S-K. Please revise to expand your discussion of foreign currency risk to comply with one of the disclosure alternatives in Item 305(a) of Regulation S-K.

Quantitative and qualitative disclosure about market risk, page 70

  1. Please tell us how you considered the disclosures required by Item 305(a) of Regulation S-K with respect to your term loan.

Item 7A. Quantitative and Qualitative Disclosure About Market Risk

Foreign Currency Risk, page 125

  1. Please tell us what consideration you gave to providing a sensitivity analysis for each currency (e.g., British Pounds and Euro) that may have an individually significant impact on future earnings.

Item 7A – Quantitative and Qualitative Disclosures About Market Risk, page 30

  1. We note your quantitative disclosure of interest rate risk associated with your investments in cash and cash equivalents and investment securities. We also note that your disclosure does not address market risk for other financial instruments such as the senior unsecured notes. Please revise to include qualitative and quantitative information about market risk in accordance with one of the three disclosure alternatives within Item 305 of Regulation S-K and that addresses the interest rate risk for the senior unsecured notes.

Evolution of the Audit Committee – Part Five – Voluntary Disclosures in the News

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Over the last two months we have done a series of blog posts about audit committee oversight and disclosure issues. One of the major topics under discussion within, among and about audit committees is what information should they disclose about their oversight of the audit, financial reporting and ICFR processes. Most observers agree that effective audit committee oversight is critical to success in these areas. And, many also believe that more information about how individual audit committees exercise this oversight will be valuable to investors and other stakeholders.

In our post on October 30 we reviewed the SEC’s Concept Release discussing possible incremental disclosures about this oversight. You can review it here:

seciblog.pli.edu/?p=462

Out in the real world it turns out that many companies are voluntarily making disclosures beyond those currently required by the SEC. On November 3, 2015 the Center for Audit Quality and Audit Analytics released their second “Audit Committee Transparency Barometer”. This “Barometer” is a survey of actual audit committee disclosures. Interestingly, this report shows that many companies are voluntarily going beyond required audit committee disclosures.

If you are not familiar with the CAQ you can read about it in our June 16, 2015 post at:

seciblog.pli.edu/?p=405

The press release about this second “Barometer” report and a link to the full report are at:

www.thecaq.org/newsroom/2015/11/03/second-annual-audit-committee-transparency-barometer-reveals-encouraging-disclosure-trends-for-public-companies-of-all-sizes

It makes for very interesting reading and provides valuable information in the search for “best practices” for audit committee disclosures. The report focuses on audit committee disclosures about external auditor oversight for companies in the S&P Composite 1500. As you read it you will see many companies voluntarily disclose information about topics ranging from issues considered in recommending the audit firm for appointment/reappointment to the audit committees role in selecting the engagement partner.

 

As always, your thoughts and comments are welcome!

Debt Versus Equity – More on Ratchets

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On November 3 we blogged about debt versus equity issues and how in late stage financings investors were demanding price adjustment and conversion rate adjustment features such as ratchet provisions. In essence this was to protect late round investors if the valuations they used for their investment was substantially higher than the IPO valuation.

As you may have been following, Square has just completed their IPO. Here is an excerpt from Square’s stockholder’s equity note in their financial statements:

The initial conversion price for the convertible preferred stock is $0.21627 for the Series A preferred stock, $0.71977 for the Series B-1 preferred stock, $0.95369 for the Series B-2 preferred stock, $5.79817 for the Series C preferred stock, $11.014 for the Series D preferred stock, and $15.46345 for the Series E preferred stock. In the event the Company issues shares of additional stock, subject to customary exceptions, after the preferred stock original issue date without consideration or for a consideration per share less than the initial conversion price in effect immediately prior to such issuance, then and in each such event the conversion price shall be reduced to a price equal to such conversion price multiplied by the following fraction:

the numerator of which is equal to the deemed number of shares of common stock outstanding plus the number of shares of common stock, that the aggregate consideration received by the Company for the total number of additional shares of common stock so issued would purchase at the conversion price immediately prior to such issuance; and

the denominator of which is equal to the deemed number of shares of common stock outstanding immediately prior to such issuance plus the deemed number of additional shares of common stock so issued.

Series E preferred stock contains a provision for the adjustment of conversion price upon a public offering. In the event of such offering, in which the price per share of the Company’s common stock is less than $18.55614 (adjusted for stock splits, stock dividends, etc.), then the then-existing conversion price for the Series E preferred stock shall be adjusted so that, as of immediately prior to the completion of such public offering, each share of Series E preferred stock shall convert into (A) the number of shares of common stock issuable on conversion of such share of Series E preferred stock; and (B) an additional number of shares of common stock equal to (x) the difference between $18.55614 and the public offering price, (y) divided by the public offering share price.

The language above is not very easy to understand, but there are various price adjustment features and the instruments that have them were entered into at various points in time, including some later stage investments. So, the debt versus equity issues is present.

Square’s IPO priced at $9, (actually below the expected price range, but the company did get a nice day one price rise on the exchange) so Square will have to make up shares to these later stage investors. This is a simple example where late stage financing valuations were higher than the IPO price.

Here are two links to information about the transaction. Buzzfeed has a nice summary of the deal at:

www.buzzfeed.com/williamalden/square-valued-at-29-billion-in-ipo-short-of-expectations?utm_medium=email&utm_campaign=News+-+1119+Thursday&utm_content=News+-+1119+Thursday+CID_8ba44ca9bcced29cacc07f7e086f01c4&utm_source=BuzzFeed%20Newsletters&utm_term=.uxrLvq8pj#.amezg5KWJ
Here is a WSJ article where the WSJ somehow wanted to call this ratchet a “penalty”:

blogs.wsj.com/digits/2015/11/18/square-pays-93-million-penalty-to-some-investors-in-ipo/

As always, your thoughts and comments are welcome!

 

 

P.S. And, just in case this is relevant to you, here is a link to our new workshop “Debt vs. Equity Accounting for Complex Financial Instruments”. This new case-driven workshop will be presented five times next year.

www.pli.edu/Content/Debt_vs_Equity_Accounting_for_Complex_Financial/_/N-1z11c8lZ4k?ID=262917

More SAB 74 and a Draft for Your Use

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SAB 74 Disclosures are going to be important for the new Revenue From Contracts With Customers standards, so here is a starting point for your use.

First, a brief reminder of the requirements from SAB 74 (Topic 11-M in the SAB codification).  For recently issued accounting standards expected to have a material impact you should consider disclosing:

A brief description of the new standard, the date that adoption is required and the date that the registrant plans to adopt, if earlier.

A discussion of the methods of adoption allowed by the standard and the method expected to be utilized by the registrant, if determined.

A discussion of the impact that adoption of the standard is expected to have on the financial statements of the registrant, unless not known or reasonably estimable. In that case, a statement to that effect may be made.

Disclosure of the potential impact of other significant matters that the registrant believes might result from the adoption of the standard (such as technical violations of debt covenant agreements, planned or intended changes in business practices, etc.) is encouraged.

The SAB also reminds registrants of the requirement to disclose in MD&A presently known material changes, trends, and uncertainties that the registrant reasonably expects to have a material impact on future sales, revenues or income from continuing operations. We will address the MD&A discussion in a future post.

You can read the entire SAB at: http://www.sec.gov/interps/account/sabcodet11.htm#M

Here is a draft of footnote disclosure for a registrant that currently does not know the impact the standard will have. Please consider this disclosure only as a starting point, to be edited with your facts and circumstances.

New Accounting Standards

On May 28, 2014 the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) No. 2014-09, Revenue from Contracts with Customers (Topic 606). The ASU establishes a new, contract-based model for recognizing revenue.  The new model replaces virtually all of the existing generally accepted accounting principles for revenue recognition that currently exist in US GAAP.  The new model is based on five steps, (1) identifying contracts with customers, (2) identifying performance obligations within each contract, (3) determining the transaction price, (4) allocating the transaction price to performance obligations and (5) recognizing revenue when or as a performance obligation is satisfied.  The new model significantly changes existing GAAP, requires substantial judgment in its application, and will generally require companies to make more disclosures about revenue.

Public business entities must implement the new Accounting Standards Update for annual reporting periods beginning after December 15, 2016, including interim reporting periods within that year. Earlier application is not permitted.  Thus, we will implement the new standard for the quarter beginning on_________.

The new standard provides for two alternative implementation methods.  The first is to apply the new standard retrospectively to each prior reporting period presented.  This method does allow the use of certain practical expedients.

The second method is to apply the new standard retrospectively in the year of initial adoption and record a cumulative effect adjustment for the impact of adjusting contracts open at the date of adoption.  Under this transition method, we would apply this guidance retrospectively only to contracts that are not completed contracts at the date of initial application (which for us will be January 1, 2017).  We would then recognize the cumulative effect of initially applying the standard as an adjustment to the opening balance of retained earnings. This method also requires us to disclose comparative information for the year of adoption.

We have not yet determined which method we will use to implement the new standard.

We have not yet determined the impact the new standard is expected to have on our financial statements or on other matters or aspects of our business.

Comment of The Week

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If you have attended one of our seminars or workshops, you know we always discuss the SEC’s Comment focus areas.  We do this so that potential problems and issues can be addressed before they become serious.

In our blog, we thought we would reinforce this with a semi-regular “Comment of the Week” entry.

And what would be a better topic to start with than reporting segments!  The SEC always mentions this area when they speak, and they continue to write comments about segments.  Here are two examples from letters issued this year:

1. We reference the disclosure on page 66 that you operate and account for your results in one reportable segment, the design, development, manufacture and market of high performance semiconductor products. Please tell us how you considered the guidance in FASB ASC 280-10-50-1 through 9. In this regard, we note that you have five major focused product groups, each of which has a Senior Vice President and General Manager that oversees its operations and may be considered a segment manager. Please clarify why these product groups do not represent segments or aggregated segments under FASB ASC 280.

7. You disclose your business is classified by management into three reporting segments. Further, we note your 2014 first quarter earnings transcript where you state, “[I]n terms of sales comparisons geographically, for the first quarter, the better performing regions in the U.S. were in the Southeast, Midwest, and Texas. Internationally, in local currencies, the better performing countries were Canada, Mexico, and Australia.” Please provide us with your analysis under ASC 280 that supported disclosing all operations as three reportable segments.

Please include the following information in your response:

  • The operating segments you have identified in accordance with ASC 280- 10-50-1 through 50-9.
  • If applicable, the basis for aggregating identified operating segments into three reportable segments given the aggregation criteria in ASC 280-10-50-11 and quantitative thresholds in ASC 280-10-50-12.
  • How the aggregation of all of your operations into three reportable segments complies with the aggregation criteria.
  • The process through which your chief operating decision maker reviews information to make decisions about resources to be allocated to your segments and assess their performance.

Why does the SEC consistently, year after year focus on this area?  As a reminder, check out the enforcement case against Sony, where their segments masked an issue in their movie business.

http://www.sec.gov/litigation/admin/3440305.txt

Or more recently, check out the enforcement case against Paccar, a Fortune 200 company that, among other issues, presented one reportable segment. As a result, the aggregation of two operating segments into one masked sizable losses in their largest segment.

http://www.sec.gov/litigation/litreleases/2013/lr22711.htm

XBRL Starting to Bubble-Up to the Comment Letter Surface?

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One of the questions that SEC reporting companies have asked about XBRL (among the many questions we ask about XBRL!) is when will the SEC start to write comments about XBRL submissions?

Very few companies have ever seen a comment letter include any mention of their XBRL submissions.

It appears that comments may be starting to be issued about XBRL.  One of the ways the SEC sends messages in in a kind of generic comment letter that they call a “Sample Letter Sent to Public Companies”, which we refer to as a “Dear CFO Letter”.

While this seems to lack the impact of a comment letter sent directly to a company, the Dear CFO Letter is actually just as important as a directly received comment letter.  It is a message to a broad group of companies about an issue that the SEC thinks is pervasive, and is, in essence, a broadly transmitted comment letter.

The most recent Dear CFO Letter actually deals with XBRL!  You can find it at:

http://www.sec.gov/divisions/corpfin/guidance/xbrl-calculation-0714.htm

The letter reminds registrants to be sure to include all calculation relationships.

It also includes this language:

“Acceptance of your filing by EDGAR does not mean that your filing is complete or in compliance with the Commission’s requirements.”

This Dear CFO letter coupled with the XBRL report we blogged about last week could be the start of a greater emphasis on XBRL matters in filings.

We would love to hear your comments!  Leave them here or email Carol or George.

XBRL – An SEC Report!

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The SEC broke its long silence about XBRL and raised some interesting questions for filers yesterday with an XBRL report from the Division of Economic and Risk Analysis titled “Staff Observations of Custom Tag Rates”.

The fairly brief report is available at:

http://www.sec.gov/dera/reportspubs/assessment-custom-tag-rates-xbrl.html#.U7wGKYm9K0d

Interestingly, the report notes that smaller filers use custom tags at a significantly higher rate than larger filers, and that this pattern can even be associated with which XBRL tools are used.  The report raises some very significant questions for filers in the smaller filer category.

One other XBRL discussion point for this blog – have you found an XBRL user focused analysis tool yet?  Check this one out from CalcBench, it is interesting!

http://www.calcbench.com

There are clearly many questions still to be addressed concerning XBRL.  We would love to hear your comments!

Updates as we Climb the Learning Curve at the SEC Institute Division of PLI

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When the Practising Law Institute acquired the programming assets of the old SEC Institute we all knew change was needed.

Since PLI is a not-for-profit organization, trying to be sure we were true to the not-for-profit mission of PLI meant we had to think about new ways to do things.  And, the old SEC Institute model had to be updated to make the programs economically sustainable.

With the transaction not happening until January of this year, we also knew we had to put our plans for 2014 together very quickly.  Just finding locations for our workshops and seminars was a huge challenge, but we did not want to go for half a year without offering  you our programs.

Of course, our first priority was making sure our seminars and workshops hit the same quality mark that you have always expected.

As we hustled to get our calendar out and deal with all of the other tactical issues, we knew we would learn in this process.  And, we have.

From our participant feedback so far this year we are already making changes.

We are changing the facilities we are using, trying to work more in our state-of-the-art PLI training centers where all attendees will find iPads at their seat with electronic access to the course materials, are providing handouts of all presentation materials and will make available electronic copies after the seminars for downloading, and are fine tuning the  hotels to fit your expectations.

For example, we are moving our 10th Annual SEC Reporting & FASB Forum for Mid-sized & Smaller Companies in September back to the Four Seasons in Las Vegas.

And we will now provide lunch to all participants of our workshops and seminars.

We want to keep learning and be sure we offer programs the way you want them to be offered, so the last part of this post is a request for any feedback you have to offer.  We will listen and we will respond.

You can email our instructors, George Wilson or Carol Stacey, or our program attorney, Robin Goldstein at the email addresses below.

Thank you for taking time to help us!

gwilson@pli.edu

cstacey@pli.edu

rgoldstein@pli.edu