We have been posting in recent weeks about issues to be thoughtful about as we approach our next quarter or year-end.\u00a0 MD&A is always an area for care and clear focus at period end.\u00a0 In all our SEC reporting workshops we make the point that the SEC frequently comments on MD&A.\u00a0 The themes of MD&A comments are generally deeper analysis of causal factors and quantification of the impact of factors on operations and liquidity and capital resources.<\/p>\n
To really understand the comments, and to write MD&A effectively, it is always smart to review the objectives of MD&A disclosure.\u00a0 Here is the articulation of these objectives from the 2003 Release FR 72<\/a>:<\/p>\n .\u201cThe purpose of MD&A is not complicated. It is to provide readers information “necessary to an understanding of [a company’s] financial condition, changes in financial condition and results of operations.”2<\/sup><\/a>\u00a0The MD&A requirements are intended to satisfy three principal objectives:<\/p>\n Here are a few example comments you can use in your thoughts about MD&A disclosures.\u00a0 The first one is about taxes and relates to causal factors.<\/p>\n This second comment is about clearly explaining and quantifying what issues are behind change in revenues so that readers can understand why revenues changes and assess whether such changes are likely to continue to occur in the future.<\/p>\n Revenues, page 30<\/p>\n We hope these reminders help as you work towards quarter or year-end, and as always, your thoughts and comments are welcome!<\/p>\n","protected":false},"excerpt":{"rendered":" We have been posting in recent weeks about issues to be thoughtful about as we approach our next quarter or year-end.\u00a0 MD&A is always an area for care and clear focus at period end.\u00a0 In all our SEC reporting workshops we make the point that the SEC frequently comments on MD&A.\u00a0 The themes of MD&A … Continue reading A Few MD&A Thoughts for Quarter or Year End<\/span> \n
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\n2016. While we note from your disclosure that revenue decreased by approximately $14 million due to near completion of projects in your e-ID division, and it appears that those revenue losses were partially offset by revenue gains from other divisions, it is not clear how you have accounted for all material changes in your revenues for the periods presented. Please tell us what the numbers in the last sentence of this paragraph represent in terms of dollar amounts and show us how those revenue gains, combined with your revenue losses, account for all material changes in your revenue for the periods presented. In addition, revise future filings to clearly disclose and quantify the reasons underlying each material change in your revenues for the periods presented.<\/li>\n<\/ol>\n