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Recent SEC Enforcement Actions Involving Accounting Misstatements and Non-GAAP Financial Measures

In July  2020, a publicly traded pharmaceutical company entered into a settlement with the Securities and Exchange Commission, without admitting or denying findings, and agreed to pay a financial penalty relating to various...more

SEC Staff Guidance on Disclosures and Financial Reporting in Light of COVID-19

On June 23, 2020, the Division of Corporation Finance (Division) of the US Securities and Exchange Commission (SEC) issued CF Disclosure Guidance: Topic No. 9A (CF 9A), providing guidance on operations, liquidity, and capital...more

SEC Chief Accountant Addresses COVID-19

In recent remarks, the Chief Accountant noted that the Securities and Exchange Commission’s Office of the Chief Accountant (OCA) and other divisions within the SEC are monitoring the issues raised by COVID-19....more

AICPA Conference Comments on LIBOR

We previously blogged about the recent AICPA conference. At the conference, representatives from the Office of Chief Accountant also shared some views regarding the discontinuation of LIBOR. The Staff of the OCA joined in the...more

The Role of the Office of the Chief Accountant and Office Priorities

At the AICPA conference we have previously blogged about, the Chief Accountant explained that the SEC’s Office of the Chief Accountant (“OCA”) is led by the Chief Accountant, who serves as the principal advisor to the SEC on...more

Disclosure Tone after Financial Misconduct

In a recent paper titled “Damage Control: Changes in Disclosure Tone After Financial Misconduct,” authors Rebecca L. Files, Alex Holcomb, Gerald S. Martin, and Paul Mason assess how companies change the tone of their required...more

Effect of Public Availability of Comment Letters

In a paper titled “The Effect of Enforcement Transparency: Evidence from SEC Comment-Letter Reviews,” authors Miguel Euro, Jonas Hesse and Gaizka Ormazabal study the effects of the change in policy by the Securities and...more

Report from SEC Office of the Investor Advocate

Before the SEC shutdown, the Office of the Investor Advocate published the annual report on its activities during 2018. ...more

Legal Update: Will the Earnings Release Be the New 10-Q?

On December 18, 2018 the Commission published a Request for Comment on Earnings Releases and Quarterly Reports (the “Request”), which solicits public comment on both earnings releases and the frequency of periodic reporting....more

Financial Reporting and Related Guidance from AICPA Conference

Representatives from the Office of Chief Accountant discussed new accounting standards. The Staff commented on the implementation of the new revenue recognition standard, which requires companies to provide a comprehensive...more

Integrity of Financial Reporting and Foreign Issuers; China-Based Issuers

On Friday, the Chair of the Securities and Exchange Commission Jay Clayton, the Commission’s Chief Accountant Wes Bricker, and the Chairman of the PCAOB William Duhnke issued a statement reaffirming the significance to the...more

From Non-GAAP Measures to KPIs…

In a recent speech, Commissioner Kara Stein addressed a number of disclosure related concerns, including cyber disclosures and ESG disclosures. Just as many of us had been reading about a decline in the number of SEC Staff...more

Wording in SEC Comment Letters to FPIs

In an interesting paper titled “The Power of Words in Capital Markets: SEC Comment Letters on Foreign Issuers and the Impact of Domestic Enforcement,” authors Daniel Giamouridis, Kleopatra Koulikidou and Stergios Leventis...more

Ending Quarterly Filings? Or Just Discontinuing Quarterly Guidance?

Even before the Trump tweet, discussions regarding interim reporting requirements for U.S. public companies had been ongoing for several years. ...more

Commission Responds to Tweet

As we previously blogged, a Trump tweet called on the Securities and Exchange Commission to undertake a study regarding the costs and benefits of quarterly versus semi-annual filings. ...more

Chief Accountant’s Remarks Regarding Financial Reporting

The Securities and Exchange Commission’s Chief Accountant, Wesley Bricker, addressed attendees at a conference of the Institute of Management Accountants. ...more

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