Latest Posts › SEC Comment Letter Process

Share:

Recent SEC Comment Letter of Interest Regarding Whether a Digital Currency is a Security Under Section 2(a)(1) of the Securities...

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 your attention to a recent SEC comment letter exchange...more

A Survey of Recent SEC Comment Letters on Human Capital Disclosures

Late last year, the Securities and Exchange Commission (SEC) adopted amendments to modernize the description of business, legal proceedings, and risk factor disclosures that registrants are required to make according to...more

Adjusting for Litigation Expenses in a Non-GAAP Financial Measure

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

How a Surge in E-Commerce Sales Could Impact Financial Reporting; A Look at ASC 606 and Disaggregated Revenue

Over the past eight months of this pandemic, we have all seen the rise of e-commerce as a vital necessity for most companies. For many companies, e-commerce has significantly outperformed their existing sales channels and...more

Recent SEC Comment Letter Reveals the Difference Between Prescriptive-Based and Principles-Based Rules

As we have previously discussed, on August 26, the Securities and Exchange Commission (SEC) voted to adopt amendments to modernize the description of business (Item 101), legal proceedings (Item 103), and risk factor (Item...more

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

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

SEC Staff Comments on Chegg’s Data Breach Disclosure and Response; A Real Life Example

One thing I appreciate about the SEC comment letter process is that it gives real life examples to what is often discussed hypothetically. Take, for example, cybersecurity and steps management should take when a data incident...more

“Dick Clark’s Rockin’ Eve with Ryan Seacrest” Gets a Billion TV Viewers? SEC Staff Says Prove It

It’s not too often we see Dick Clark and Ryan Seacrest mentioned in SEC comments, so this recent SEC comment letter issued to Planet Fitness caught our attention. The Staff’s letter to Planet Fitness indicates that it...more

5 Interesting Takeaways from Uber Technologies’ IPO SEC Comments

While monitoring SEC comment letters, we recently came across the batch of SEC comment letters issued to Uber Technologies, Inc. in connection with its IPO registration statement that was declared effective on May 9, 2019. ...more

Behind the SEC Curtain - Practical Tips for Interacting with the SEC Staff

I recently presented to the Corporate & Securities Law Committee of the Association of Corporate Counsel (ACC) on the topic entitled “Behind the SEC Curtain: Practical Tips for Interacting with the SEC Staff.” The...more

SEC Comment about “Affiliate” Stockholder in Public Float Calculation

In monitoring SEC comment letters, we came across this SEC comment letter made public this month. It serves as a reminder to registrants that, when calculating a company’s public float, there is an informal presumption that a...more

11 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide