By George M. Wilson & Carol A. Stacey<\/p>\n
In recent weeks we have been posting about areas to deal with in advance of year-end. So far we have addressed:<\/p>\n
Issues in the Statement of Cash Flows<\/u><\/a><\/p>\n Evaluating and Auditing ICFR<\/u><\/a><\/p>\n The New Item 16 Form 10-K Summary<\/u><\/a><\/p>\n Recently Issued Accounting Standards and a Few Example Comments<\/u><\/a><\/p>\n SAB 74\/Topic 11-M \u2013 News from the SEC at the September EITF Meeting<\/u><\/a><\/p>\n Disclosure Effectiveness<\/u><\/a><\/p>\n Should You Consider Any Issues for OCA Consultation?<\/u><\/a><\/p>\n A Year End Planning Detail \u2013 No More Mailing the ARS to the SEC!<\/u><\/a><\/p>\n Three Years of Fun \u2013 Planning the \u201cBig Three\u201d New FASB Statement Transitions<\/u><\/a><\/p>\n <\/p>\n As we are getting ever closer to year-end this is also a good time to proactively review areas where financial reporting problems frequently occur<\/strong> and take steps to assure we have all the \u201ci\u2019s\u201d dotted and \u201ct\u2019s\u201d crossed in these areas.<\/p>\n Unusually complex accounting issues, difficult estimates and sensitive disclosures all become the focus of SEC comments. This is not because the Staff thinks they are important in and of themselves, but rather because these are areas where the Staff frequently uncovers problems in the comment process. Clearly if we do not deal with them appropriately, they involve risk of restatement and amendment.<\/p>\n There are a variety of ways you can keep up with the CorpFin Staff\u2019s frequent comment areas. Every year at our Annual Reporting Forums in November and December, our Conference for Mid-Size and Smaller Companies in September and our Mid-Year Programs in May and June current and former Staffers discuss the areas where they have concerns.<\/p>\n Here is the list from our most recent programs:<\/p>\n Beyond hearing from the Staff and those in the know, many organizations research comment letters and summarize the areas and frequency of comments within these areas.\u00a0\u00a0 You can find these summaries on the web pages for most of the national CPA firms. Here are links to some of them:<\/p>\n EY SEC Comments and Trends<\/u><\/a><\/p>\n Deloitte\u2019s SEC Comment Letter Series<\/u><\/a><\/p>\n PWC\u2019s SEC Comment Letter Trends<\/u><\/a><\/p>\n Other companies build databases of comments which can be researched by comment area, CorpFin Office and even by reviewer. Two companies who sell these kinds of tools are Audit Analytics<\/u><\/a> and Intelligize<\/u><\/a>. However, remember the Staff\u2019s caution that their comments are fact-specific to each registrant and you should never cut and paste from another letter.<\/p>\n If you have any other good sources of information about these issues, please leave them in a comment to this post, and, as usual, your thoughts and comments are welcome!<\/strong><\/p>\n <\/p>\n <\/p>\n <\/p>\n","protected":false},"excerpt":{"rendered":" By George M. Wilson & Carol A. Stacey In recent weeks we have been posting about areas to deal with in advance of year-end. So far we have addressed: Issues in the Statement of Cash Flows Evaluating and Auditing ICFR The New Item 16 Form 10-K Summary Recently Issued Accounting Standards and a Few Example … Continue reading Year-End Planning \u2013 More or Less Concluded \u2013 Keeping Up with SEC Focus Areas<\/span> \n