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SEC Comment Letter Process Generally Accepted Accounting Procedures

Bass, Berry & Sims PLC

Adjusting for Litigation Expenses in a Non-GAAP Financial Measure

Bass, Berry & Sims PLC on

It should come as no surprise to readers of our blog that public companies often expend significant resources each year on managing litigation matters. As a result, perhaps it is natural that some companies might want to...more

Bass, Berry & Sims PLC

Recent SEC Comment Letters Of Interest Regarding COVID-19 Adjustments, SAB 99 And South Korea

Bass, Berry & Sims PLC on

Subscribers to our blog know that we monitor EDGAR for new SEC comment letters and enjoy bringing attention to the more interesting ones. In today’s blog post, we bring you three new SEC comment letter exchanges. •In the...more

Mayer Brown Free Writings + Perspectives

Survey of Recent SEC Comment Letters to Mortgage REITs

In recent years, the Staff of the Securities and Exchange Commission (the “SEC”) has been providing comments regarding companies’ presentations of non-GAAP financial measures in public filings. ...more

A&O Shearman

It’s Annual Report Time—Recent Developments and Trends for the Preparation of Form 20-F - 2019

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It is now time for foreign private issuers to prepare their annual reports on Form 20-F. For companies with a calendar year-end, the Form 20-F must be filed with the U.S. Securities and Exchange Commission (the SEC) by 30...more

Opportune LLP

2018 SEC Comment Letter Trends & Disclosure Best Practices

Opportune LLP on

As we wind down the third quarter of 2018 and turn our attention toward year-end disclosures, it is helpful to review U.S Securities and Exchange Commission (SEC) comment letter trends to improve financial statement...more

Mayer Brown Free Writings + Perspectives

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

Dorsey & Whitney LLP

Analysis of the 60 Most Recent SEC Comment Letters Issued to Canadian Form 40-F Filers

Dorsey & Whitney LLP on

Since January 1, 2016, the SEC has publicly released its correspondence relating to 60 comment letters sent to Canadian issuers with respect to annual reports filed on Form 40-F pursuant to the Canada-U.S....more

A&O Shearman

Updated Non-GAAP Guidance: The First 150 Comment Letters

A&O Shearman on

In May of this year, the staff of the SEC’s Division of Corporation Finance updated its C&DIs regarding the use of non-GAAP financial measures. We summarized the May 2016 update in an earlier client publication. Since the...more

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