Thursday, March 21, 2019
Tech Data’s Goodwill Adjustment

Tuesday, March 19, 2019
There’s Taxes, and There’s Taxes

Saturday, March 16, 2019
Adventures in Tax Cuts and Net Income

Monday, March 11, 2019
Big Moves in Goodwill, Intangible Value

Friday, March 8, 2019
CVS, Goodwill, and Enterprise Value

Thursday, February 28, 2019
Summary of Our Goodwill Research/ How-To

Wednesday, February 27, 2019
What Does ‘Other’ Mean? An Example

Thursday, February 21, 2019
Another Tale, Buried in the Footnotes

Wednesday, February 13, 2019
Low Latency Calcbench

Monday, February 11, 2019
Now Streaming on Hulu: Red Ink

Thursday, February 7, 2019
Early Look at 2018 Tax Decline

Wednesday, February 6, 2019
You Revised WHAT, Netflix?

Thursday, January 31, 2019
Talking About Huawei Exposure

Wednesday, January 30, 2019
Another Discrepancy in Reported Numbers

Wednesday, January 30, 2019
Finding Revised Facts: Hertz Edition

Wednesday, January 23, 2019
GE Commercial Aviation Services: Bringing Numbers to Light

Monday, January 21, 2019
Differences in Earnings Releases and 10-Ks

Wednesday, January 16, 2019
The Importance of Textual Analysis

Tuesday, January 8, 2019
A Look at Climate Change Disclosures

Wednesday, January 2, 2019
Quants: Point-in-Time Data for Backtesting

Archive  |  Search:
More Thoughts About Comment Letters
Friday, January 20, 2017

You may wonder about the hip, edgy podcasts that we here at Calcbench follow, because we are so hip and edgy ourselves. Well, one that we sometimes enjoy is the CFO Direct podcast from PwC, which airs roughly once a month to talk about of-the-moment reporting issues.

Yes, we’re just that cool.

The most recent podcast examines trends in 2016 comment letters from the SEC. As you prepare your annual filings for later this spring, or if you want ideas on what topics you may want to research through the Calcbench databases, this one is worth a listen.

One of the speakers, Wayne Carnall (former chief accountant at the SEC, now partner with PwC), noted that lots of comment letters recently focus on complex matters of judgment. For example, you may want to include a non-GAAP performance metric in your filing, and you calculate that non-GAAP metric by excluding a few items. That idea can be acceptable, Carnall said, but if your metric eliminates some expenses that are necessary for your business to function—well, that non-GAAP metric won’t pass the smell test with SEC staff.

Or you might want to change your presentation of non-GAAP metrics from one filing period to another. Is that appropriate? The answer depends on how much of an explanation you give about why the change in presentation makes sense, Carnall said. If a company is changing its presentation simply to make its performance look better, a comment letter might be in your future.

We mention all this because Calcbench does let you research and track SEC comment letters. You can see one previous post on how to find comment letters; and another on the wisdom of following your peers’ and competitors’ comment letters, to gauge whether any reporting practices you’re following might get a comment letter too. And you can see a whole other post about forming a peer group as well.

Meanwhile, we’re going back to listening to this podcast about comment letter trends. Stay hip, people.

FREE Calcbench Premium
Two Week Trial

Research Financial & Accounting Data Like Never Before. More features and try our Excel add-in. Sign up now to try the Premium Suite.