We didn’t plan this, we swear—but one day after our post about how Calcbench users can easily find and read SEC comment letters, the SEC itself gave the perfect example of why you might want to do so.
That example came in the form of comment letters sent to LendingClub, prodding the online lender about its use of non-GAAP accounting metrics. The SEC and LendingClub swapped a series of letters over the summer, as part of the SEC’s regular review of public filers’ financial accounting.
By Nov. 4 the SEC had closed its review with no further action, and per usual routine, the comment letters became public this fall. You can read all about the LendingClub’s exchange in an article from the Wall Street Journal today.
Sympathetic souls might think, “Yuck, that must have been an unwelcome surprise from the SEC.”
Well, no. Not if you keep on the lookout for SEC’s comment letters to your competitors, to see whether questions they receive might eventually become questions you receive, too.
For example, On Deck Capital, an online lender to small businesses, also received SEC comment letters over the summer inquiring about On Deck’s non-GAAP metrics. Another competitor, Prosper Marketplace, had extensive correspondence with the SEC in 2015 over its registration statement.
All of that correspondence has been tucked away in Calcbench’s databases for many months. Comment letters typically don’t become public on the SEC EDGAR database until 20 days after they are sent—but once they are available, then like all SEC filings, they are indexed and added to the Calcbench empire immediately.
For financial reporting professionals, then, keeping tabs on your competitors’ comment letters is a great way to stay ahead of what might be coming your way, too. And keeping tabs has never been easier on Calcbench.
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