Senior SEC official comments on key public reporting disclosure issues

By Ed Batts

At a recent American Bar Association meeting, a senior Securities and Exchange Commission (SEC) official reviewed various aspects of interest for public company reporting and compliance purposes. As is customary, such staff comments were on a non-attribution basis and were represented to be personal views only and not those of the SEC as a whole. Nonetheless, such informal commentary continues to offer contextual perspective on both current matters and, equally importantly, indicates areas of less current significance at the SEC.

Notably, the staff have been exceeding the Sarbanes-Oxley-mandated goal of reviewing financial statements at least once every three years. The corporate finance division has 500 members, a number that has not changed since before the adoption of Sarbanes-Oxley. The staff reviews the largest companies annually and, in the case of financial services firms, reviews multiple times per quarter.

The growing volume has led to a reduction in the sheer number of comments and an intentional emphasis on the judgment of the professional staff in both accounting and legal reviews…

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