On June 24, 2024, Corporation Finance Director Eric Gerding gave an Announcement titled “The State of Disclosure Review,” and stated that “[t]his is part of an initiative to be more transparent and communicate with the marketplace about what is going on in the Disclosure Review Program.”

In his remarks Mr. Gerding describes the objectives of the review program and provides an overview of the review process.  He notes that approximately 3,300 companies were reviewed in 2023.  He enumerates frequent comment areas including China-related matters, non-GAAP measures, MD&A, revenue recognition, and financial statement presentation.  He also discusses disclosure priorities including artificial intelligence, disclosures by China-based companies, and commercial real estate as well as how CorpFin will address recently issued rules.

The announcement provides a very thorough and comprehensive discussion that will inform all professionals in the reporting process about the priorities and approach of the filing review process.

As always, your thoughts and comments are welcome.