What’s trending in 2023 SEC comment letters

With year-end reporting around the corner, we kick off our 2023 SEC comment letter trends series, in which our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance.

This week, Heather Horn is joined by Kyle Moffatt, PwC National Office Professional Practice Leader, to share an overview of the 2023 comment letter trends, a breakdown of the SEC’s review process, and insights into the SEC staff’s key priorities.

In this episode, you’ll hear:

• 2:01 - A breakdown of the SEC review process, including the staff’s current priorities, review timing, and key enforcement actions
• 18:28 - The impact of a potential government shutdown on the SEC’s review process and on the capital markets more broadly
• 22:43 - An overview of the the top SEC comment letter trends in 2023
• 29:14 - Insights into changes in the SEC’s priorities and volume of comment letters, updates on the climate disclosure proposal, and 2024 enforcement priorities
• 34:11 - Key insights into what preparers should focus on, including the importance of “Dear Issuer” letters and reminders for new rules that are effective in 2024
• 39:13 - Final advice for preparers entering the year-end reporting season

Want to learn more? Check out our analysis of SEC comment letter trends. Additionally, follow PwC’s accounting podcast on your favorite podcast app for future episodes in this SEC comment letters series, and subscribe to our weekly newsletter to get all of our thought leadership. 

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.