You can set the default content filter to expand search across territories. 5 The Commission is generally implementing the supporting objective. Few successful actions for implementation exist and many obstacles impair the unit's ability to implement the supporting objective . Click here to extend your session to continue reading our licensed content, if not, you will be automatically logged off. }); Your go-to resource for timely and relevant accounting, auditing, reporting and business insights. It also highlights areas the SEC staff may focus on next, such as disclosures related to the new standards on leases and credit losses and the potential effects of Brexit and the market transition to LIBOR. Qualitative Analysis It is for your own use only - do not redistribute. The analysis herein summarizes the Sub-elements relating to the comment letter process are distributed throughout the six general categories. Once the new standard goes into effect on June 30, 2020, FINRA will start examining firms actual compliance with Reg BI and its new customer relationship summary disclosures. The staff examiner performs the initial review of the filing for compliance with applicable securities laws. SEC comment letter industry insights and trends has been saved, SEC comment letter industry insights and trends has been removed, An Article Titled SEC comment letter industry insights and trends already exists in Saved items. They thought the policy made it appear as if the foreign issuers were being "favored." 1 The Commission is not implementing the supporting objective in a meaningful manner. Information in this publication is based on How does the health equity ecosystem move from awareness to action? Very limited successful actions for implementation exist and obstacles are so prevalent that the unit is significantly impaired from implementing the supporting objective. SEC Comment Letter All rights reserved. 3 tactical moves for oil and gas companies in 2023, Select your location Close country language switcher. We designed the workshops to be homogeneous with respect to management or professional staff to facilitate subsequent comparisons. Another letter signed by over five hundred investors, foundations, companies, lawmakers, and NGOs, expresses support for SEC rulemaking by noting that "climate change poses a variety of material risks to companies of all sizes in all industries across our nation.". By providing your details and checking the box, you acknowledge you have read the, The following fields are not editable on this screen: First Name, Last Name, Company, and Country or Region. The Office facilitator recorded the rating for each participant on the flipchart. The electronic documents were then placed on the Division's file server. The Securities and Exchange Commission's Office of Inspector General (Office) evaluated the Division of Corporation Finance's (Division) comment letter process. influence comment letter trends. The Division should design and implement formal training for reviewers. In accordance with a directive from the then acting chair of the SEC to focus on climate-related disclosures, the SEC staff also began issuing comments on climate-change disclosures for the first time in several years. The Commission receives thousands of filings each year by issuers registering securities and submitting required reports and schedules. Some participants felt that some reviewers change the comments on a filing, or insert new comments, without notifying them. Do Not Sell or Share My Personal Information. Workshop participants agreed that the current process works well in resolving comments. Click here to extend your session to continue reading our licensed content, if not, you will be automatically logged off. 22 percent of the Forms 10-K filed. Division performs some level of review of each registrant at least once every three These potential measures include: the cost of the filing review function versus the dollar volume of the markets; the cost of the review as a percent of the filing fee; the dollar amount of changes in financial statements based on filing reviews; the number of material comments on filings with unqualified ("clean") audit opinions; the number of filings with comments implemented; the number of foreign companies that file with the SEC; and the value of fraudulent offerings stopped. We also expect the SEC staff to continue monitoring the effects of the COVID-19 pandemic, the Russia-Ukraine war, supply-chain disruptions, labor shortages, inflation, and rising interest rates, as well as other emerging market events, and perhaps focus future comments on accounting and reporting related to these matters. About 6.5% of the CTRs (1% of the overall sample) are related to Rule 406. Management Review However, despite these concerns, participants indicated they were proud to work for the Commission, in particular the Division. The Office prepared the audit report. The participants agreed that, taken as a whole, the Division's comment letter process was achieving its primary objective to improve disclosure to investors. These letters set forth staff positions and do not constitute an official expression of the SECs views. Bloomberg. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. The sample comment letter includes an illustrative, non-exhaustive list of comments that the SEC's Division of Corporation Finance may issue to companies about their climate-related disclosure or the absence of such disclosure. Also, in a 1996 speech, senior Division management indicated that staff comments resulted in increased issuer attention in a number of disclosure areas, including accounting for disposal of assets as discontinued operations, presentation of overly broad geographic segments, and use of valuation allowances. This message will not be visible when page is Focus Areas Relating to Investment Advisers, Investment Companies, Broker-Dealers, and Municipal Advisors . Consider removing one of your current favorites in order to to add a new one. We also observed an increased number of comments related to acquisitions, mergers, and business combinations following a rise in merger and acquisition activity over the past several years. Lack of flexibility in work hours concerned some staff. KPMG webcasts and in-person events cover the latest financial reporting standards, resources and actions needed for implementation. The printed document may contain agency comments, charts, photographs, appendices, footnotes and page numbers which may not be reproduced in this electronic version. In addition, during the current year, approximately 50% of reviews with comment letters were for registrants generating $1 billion or more of revenue, although these larger registrants represented only 22% of the Forms 10-K filed. future area of focus for sec comment letters. comments on accounting and reporting related to these matters. Background Analytics. Enabled by data and technology, our services and solutions provide trust through assurance and help clients transform, grow and operate. Workshop participants overwhelmingly reported that, although not perfect, the comment letter process is effective in improving disclosure. Staff Performance Measures, Appendix A - Control Self Assessment Methodology The Control Self Assessment (CSA) methodology used consists of four primary tasks: identify management objectives, convene workshops to discuss and rate each objective, evaluate the workshop data, and prepare an audit report. The Division converted its standard examination reports, internal division memoranda, staff manuals, legal bulletins, current issues, industry guides, and disclosure regulations to electronic form. In turn, the Chairman contacted some of the companies for feedback on their experience with the Division's filing review process. Disclosure-event abnormal returns, revenue . Select a section below and enter your search term, or to search all click It also highlights areas the SEC staff may focus on next and summarizes best practices that may help companies respond to SEC staff comment letters. Does your firm periodically test its systems to ensure these communications are being captured for review and retention? The analysis herein summarizes the comments the Division issued during its reviews of periodic filings of public companies. You must consult an attorney for advice regarding your compliance with laws and regulations applicable to your business. Follow along as we demonstrate how to use the site. Do not delete! Does your firm have a process in place to evaluate new tools available to your registered representatives to determine whether there are digital communications channels that should be captured, included in your firms routine electronic communications supervisory reviews, and stored in accordance with books and records requirements? Comments may consist of requests for supplemental information, amendments to filings, or improvements in future filings (futures comments). For more information about our organization, please visit ey.com. As a result of their review, they edit and add comments as appropriate. They felt that, in certain cases, Internet e-mail could possibly be a faster way to contact issuers. They were: Communicate Staff Findings - Document and communicate staff findings from the review of disclosure filings to supervisors by preparing examination reports and draft comments. Our internal subject matter experts and our network of external industry experts are featured with insights into the technology and industry trends that affect your electronic communications compliance initiatives. The reviewers review the examination report and draft comments prepared by the staff accountants and examiners to ensure that any material disclosure issues in the filing are identified. On September 22, 2021, the Staff of the SEC published a sample comment letter regarding climate change disclosures. Also, participants have difficulty tracking issuer changes made to electronic filings in response to comments, especially in financial statements. As registrants start to prepare for the 2022 annual reporting cycle, they may find it helpful to consider the following SEC priorities: For a comprehensive discussion of comment letter trends affecting SEC filers, see Deloittes Roadmap SEC Comment Letter Considerations, Including Industry Insights. It also highlights areas the SEC staff . We also reviewed a list of 192 companies whose filings were reviewed by the Division and that were contacted by the Chairman of the Commission to obtain feedback on their experience with the Division's filing review process. This includes retention of electronic communications such as email, text messages, instant messages, social media, and collaboration tools. Review the firms practices, policies, and procedures to confirm that these address the enforcement priorities. For more information about our organization, please visit ey.com. Staff requests futures comments when the improvements are not immediately consequential, but will improve disclosure. This issue of On the Radar contains SEC comment letter considerations, including an update on SECs priorities; a summary of comment letter trends related to the top 10 topics of frequent comment; and future SEC disclosure priorities, including climate change, financial technology, and evolving risk. The firm should be able to demonstrate adherence to the requirements during exams conducted by regulators. Asking the better questions that unlock new answers to the working world's most complex issues. Ratings for this objective indicate that participants feel that the objective is generally implemented, but that some obstacles impair full implementation of this supporting objective. To stay logged in, change your functional cookie settings. The Office generally endorses these recommendations and makes additional recommendations in its report. Workshop discussions indicated that this supporting objective received low scores from participants because of concern with the Division's use of number of filings reviewed as its primary measure of program performance. However, the issuer may also request consideration of a question by more senior Division staff. The facilitator then repeated the procedure to rate how important (or desirable) the participants thought the objective was. While this guide does not have to be a detailed checklist, nor a substitute for the reviewer's judgment, it should help provide a more consistent approach. Audit Methodology 27 11. future area of focus for sec comment letterschucks and pearls meaning. Of these, 90% resulted in changes in income of 10% or more. We use cookies to personalize content and to provide you with an improved user experience. It also highlights areas the SEC staff may . Participants agreed that the Division uses the number of filings reviewed as its primary performance measure. You can create keywords and key phrases to flag the risk of advisors using unauthorized communication channels. topics of focus in the coming year. Participants were generally pleased with the training they received. Municipal advisor examinations will include review of registration and continuing education requirements and municipal advisor fiduciary duty obligations to municipal entity clients. The Division communicates its comments to the issuer after the filing review to obtain appropriate improvements in disclosure. Firms receiving comment letters from the SEC are more likely to restate financial statements (Adams et al., 2017;Cassell et al., 2013;Heese et al., 2017; Ryans, 2020). Staff participants believed that the performance element for number of filings reviewed overshadowed the other performance rating criteria in their evaluations. Pertains to 12-month periods ended July 31 inflation, and rising interest rates affecting markets worldwide over the past year. In many instances, they had already recognized the issues and taken corrective actions. In addition, during the current year, approximately 50% of reviews with comment letters were for registrants . Some staff mentioned a perceived lack of promotion opportunity (especially to GS-14), as well as a lack of bonuses and other rewards. The standards include six general categories. Certain services may not be available to attest clients under the rules and regulations of public accounting. The examiners provided a checklist when reviewing a firms use and supervision of digital channels: Private Placement Retail Communications In addition to ongoing reviews for compliance with these core obligations, FINRA will focus on Private Placement Retail Communications. The second type of comment letters, between SEC staff and SEC filers, are contained in the SECs EDGAR database (see How to Search for EDGAR Correspondence). Please seewww.pwc.com/structurefor further details. The table below summarizes comment letter trends by topic in the Less frequently, the SEC invites public comment on Final Rules, Interpretive Releases, and Policy . expect these factors to affect the volume of comments next year as well. annual reporting cycle, they may find it helpful to consider the following SEC investors. By continuing to browse this site, you consent to the use of cookies. Smarsh provides marketing materials for informational purposes only, and such information should not be construed as legal advice or opinions. Financial_services_DM. result in increased focus and scrutiny from the SEC staff. 7 The supporting objective is extremely important and the Commission should fully implement it. Recent SEC disclosure rules and interpretive If your firm and your associated persons agree to provide account monitoring, do you apply the best interest standard to both explicit and implicit hold recommendations? PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Although issuers do not always agree with the Division's proposed changes, they generally still make them. Management and staff also agreed that the Division is composed of, for the most part, hardworking, conscientious, highly qualified and motivated staff who are dedicated to improving disclosure to investors. 12-month period ended July 31, 2022 (review year 2022 or the current Participants rated communication of comments as the most important of the six supporting objectives. These keywords or key phrases can be customized to allow the firm to control which words or phrases are flagged and to adjust them as the business changes or new risks emerge. Please see www.pwc.com/structure for further details. Our series on SEC comment letter trends continues with an area that often puts companies in the staff's spotlight: goodwill. jQuery('#chat').click(function(){ They were: Management Review - Review the examination report/draft comments for policy considerations (e.g., materiality, uniformity). Read our cookie policy located at the bottom of our site for more information. comment letters that were closed (i.e., the SEC issued a Deloittes Roadmap. To minimize the duplication, management decided to consolidate the accounting and legal comments. letters that the SEC issued to registrants) and does not 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. ttp://www.sec.gov/answers/commentletters.htm. It is for your own use only - do not redistribute. Division management indicated that they found the information extremely useful. On the Radar briefly summarizes emerging issues and trends related to the accounting and financial reporting topics addressed in our Roadmaps. Some industries have no specialized guidance. By Farzad F. Damania, Jennifer L. Howard and Ryan A. Lilley. Estimating variable consideration requires significant judgment, and the SEC asked about this judgment in 8.1 percent of its ASC 606 comment letters. Communicate Comments - Develop and communicate (written and verbal) comments to the issuers or their representatives. consistent with last years list, with the notable exception of climate-change Management Review - Review the examination report and draft comments for policy considerations (e.g., materiality, uniformity). EY helps clients create long-term value for all stakeholders. The Division provided us with an overall list including 192 companies for which information was provided to the Chairman's office between March 1997 and July 1997. One of the questions generally posed by the SEC, Fox said, is why information included in a registrant's sustainability report is not included in its Form 10-K. "I believe that the SEC staff questioning of filings will really begin to bite. See how we connect, collaborate, and drive impact across various locations. Insights. Unless noted otherwise, comment letter trend information Please refer to your advisors for specific advice. Participants indicated that issuers sometimes do not appear aware of the protections available for the supplemental material submitted to the Division. expanded disclosures related to emerging issues. Publication date: 30 Jun 2022. us SEC Comment Letter Trends. Sharing your preferences is optional, but it will help us personalize your site experience. disclosures aimed at providing decision-useful information to investors. communicating that its review is complete. Yes, subscribe to the newsletter, and member firms of the PwC network can email me about products, services, insights, and events. Communicate Staff Findings Company name must be at least two characters long. The Commission is currently seeking a contractor to modernize EDGAR. disclosures, (2) recently amended SEC rules related to the description of the These recommendations include updating review guidance as appropriate, designing and implementing formal training for reviewers, and improving the use of outcome-based program performance measures. A SPAC is a newly formed company that raises cash in an years, that trend reversed in review year 2022. The CSA methodology used in the audit consists of four primary tasks: identify management objectives, convene workshops to discuss and rate each objective, evaluate the workshop data, and prepare an audit report. Participants in several workshops indicated that the Division could be even more successful in resolving comments with more follow-up of futures comments on Forms 10K. OCIE prefaces the 2020 priorities by emphasizing the vital importance of compliance programs and compliance professionals. You may withdraw your consent at any time by emailing privacy@smarsh.com. The number of filings reviewed measures the amount of work performed by the review staff, but does not gauge the effect of the comments on filing disclosures as well as outcome-based measures. Use our Accounting Research Online website for financial reporting resources. played out over the past five years: As the chart above illustrates, while there has been a notable comments the Division issued during its reviews of periodic filings of public The Division has training for new staff examiners and accountants. Partner, Dept. We asked participants for their opinions on the pluses and minuses of working for the Commission, specifically the Division. In response, management indicated that accounting and legal comments were, at one time, presented separately in the comment letters. The term comment letters may refer either to the letters that individuals and entities submit in response to requests for public comment on SEC rule proposals or concept releases, or to correspondence between SEC staff and SEC filers. Perhaps the most noteworthy finding was that combined management and staff scores indicated that communication of comments was the most important supporting objective and the supporting objective most successfully implemented. The staff has begun issuing comments related to climate change disclosures on both annual reports on Form 10-K and registration statements. A major goal of the audit was to maximize the value of the audit to management, while maintaining auditor independence. the SEC staff often issued comments on these topics to request expanded Proquest LLC. The SEC has recently started to release the comment letters and responses. How do you move long-term value creation from ambition to action. The SECs office of compliance inspections and examinations (OCIE) released its 2020 exam priorities. OCIE notes that the positive impact of effective compliance is clear from the exams it has conducted.The OCIE 2020 priorities include the following critical areas: Financial Technology (Fintech) and Innovation, Including Digital Assets and Electronic Investment Advice OCIE recognizes that advancements in financial technologies, methods of capital formation and market structures, and registered firms use of new sources of data (often referred to as alternative data) warrant ongoing attention and review. The Division should develop a guide for reviewers to use in reviewing examination reports. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. Issues that were considered material in some groups were not always considered material in other groups, or even from reviewer to reviewer.1 No written guidance has been developed for reviewers. window.drift.on('ready', function () { At the beginning of each workshop, a senior manager from the Division introduced the workshop and provided background information on their purpose. In 2016, the percentage of comment letters issued to unique companies addressing a non-GAAP metric spiked to 35%, even as the total number of comment letters was declining, indicating non-GAAP was an area of focus for the SEC. While it is difficult to predict what new comment letter trends Questionnaires are presented after each segment and at the end of the course to obtain feedback from the participants in an effort to continuously improve the program. In particular, examinations of registered investment advisers (RIAs) will focus on RIAs that have never been examined. One of the most significant risks was missing a major issue during a filing review. Issuers and staff often discuss filing issues over the telephone throughout the review process. Prior to the workshops, each participant received a handbook that described expectations and encouraged them to think about the management objectives in advance. By providing your details and checking the box, you acknowledge you have read the, The following fields are not editable on this screen: First Name, Last Name, Company, and Country or Region. The rating scale used by the participants ranged from 7 (full implementation) to 1 (not being implemented in a meaningful manner). The SEC began publicly releasing this correspondence in 2005 for filings made after August 1, 2004 that were reviewed by the SEC staff. considering new requirements related to cybersecurity and climate disclosures, Once you have viewed this piece of content, to ensure you can access the content most relevant to you, please confirm your territory. For instance, the EDGAR system should be easier for the staff to use in uploading documents. 3 The supporting objective is relatively unimportant and its general implementation should not be a high priority at the Commission. Impact across various locations instance, the EDGAR system should be able to demonstrate to... Rating criteria in their evaluations the companies for feedback on their experience with the.. Although issuers do not redistribute assurance and help clients transform, grow and operate procedure... Promises to all of our stakeholders unimportant and its general implementation should not be construed legal. Of cookies made after August 1, 2004 that were closed (,. Laws and regulations applicable to your business will not be visible when page is focus Areas relating the... The issuer may also request consideration of a question by more senior Division staff maintaining independence! Successful actions for implementation exist and many obstacles impair the unit 's ability to implement the supporting objective is important. Staff examiner performs the initial review of registration and continuing education requirements and municipal advisors and (... Reporting related to these matters at least two characters long by the SEC has recently started release. To consolidate the accounting and legal comments in 8.1 percent of its member firms, of... Has begun issuing comments related to these matters other performance rating criteria their! To municipal entity clients the training they received for more information about our organization, please visit.. Requests for supplemental information, amendments to filings, or insert new comments especially., each of which is a newly formed Company that raises cash in an years, trend., 2004 that were closed ( i.e., the issuer after the filing review to appropriate. Not constitute an official expression of the protections available for the staff of the filing review process in report. Analysis it is for your own use only - do not redistribute well in comments! Approximately 50 % of the SECs views they found the information extremely useful most significant was... Them to think about the management objectives in advance, during the current year, approximately 50 % the! Date: 30 Jun 2022. us SEC comment letter process is effective in improving.! Uses the number of filings each year by issuers registering securities and submitting required reports and schedules believed. Never been examined Advisers ( RIAs ) will focus on RIAs that have never examined... Create keywords and key phrases to flag the risk of advisors using unauthorized communication channels 12-month... Awareness to action to demonstrate adherence to the issuers or their representatives the and! Flexibility in work hours concerned some staff policy located at the Commission is generally implementing the supporting objective they! Published a sample comment letter process are distributed throughout the six general categories do not redistribute improved experience! 3 tactical moves for oil and gas companies in 2023, Select your location Close country switcher. Participants have difficulty tracking issuer changes made to electronic filings in response, management decided to consolidate the accounting financial... Specific advice and financial reporting standards, resources and actions needed for implementation exist and many obstacles the! Office of compliance inspections and examinations ( ocie ) released its 2020 exam priorities in turn the! The Commission withdraw your consent at any time by emailing privacy @ smarsh.com participants for their opinions the! The following SEC investors for financial reporting topics addressed in our Roadmaps in, change your functional settings! Leaders who team to deliver on our promises to all of our site for more information be automatically off! Objectives in advance participant on the flipchart issuers registering securities and submitting required reports schedules! To flag the risk of advisors using unauthorized communication channels consequential, but it help! Enforcement priorities use cookies to personalize content and to provide you with improved. Result in increased focus and scrutiny from the SEC published a sample comment process. Licensed content, if not, you will be automatically logged off on a filing review long-term for... Many instances, they may find it helpful to consider the following SEC investors your! Climate change disclosures on both annual reports on Form 10-K and registration.... In increased focus and scrutiny from the SEC staff improvements in future filings ( futures comments when the are! Summarizes emerging issues and trends related to the issuers or their representatives at any time by emailing privacy smarsh.com. Of reviews with comment letters companies for feedback on their experience with the Division the. Helps clients create long-term value creation from ambition to action published a sample comment process. Judgment, and rising interest rates affecting markets worldwide over the telephone throughout the process! Have difficulty tracking issuer changes made to electronic filings in response, management that! Will help us personalize your site experience is generally implementing the supporting objective procedures to confirm these. Placed on the flipchart the workshops, each of which is a formed. The pluses and minuses of working for the Commission should fully implement it in response, management indicated they... Address the enforcement priorities to demonstrate adherence to the pwc network and/or or. Closed ( i.e., the SEC staff unless noted otherwise, comment letter process distributed. And reporting related to Rule 406 participants felt that some reviewers change comments! Our accounting Research Online website for financial reporting standards, resources and actions needed for implementation exist many... Reviewed overshadowed the other performance rating criteria in their evaluations how to use in reviewing examination reports to,... The vital importance of compliance inspections and examinations ( ocie ) released its 2020 exam priorities electronic future area of focus for sec comment letters response... For compliance with applicable securities laws on these topics to request expanded Proquest LLC requirements exams. Its general implementation should not be visible when page is focus Areas relating to Investment Advisers RIAs. Requires significant judgment, and such information should not be visible when is... Address the enforcement priorities comments as appropriate SEC asked about this judgment in 8.1 percent of ASC... Us personalize your site experience you with an improved user experience content, if not, you consent the. Had already recognized the issues and taken corrective actions 50 % of the CTRs ( 1 of! The default content filter to expand search across territories required reports and.. Accounting, auditing, reporting and business insights qualitative analysis it is for your own use only do! Information extremely useful any time by emailing privacy @ smarsh.com should fully implement it Damania Jennifer! Rates affecting markets worldwide over the past year missing a major goal of the SEC staff inflation, and Commission... Possibly be a faster way to contact issuers separately in the comment letter regarding climate change disclosures time by privacy. Auditing, reporting and business insights ) ; your go-to resource for timely and relevant,... Review of registration and continuing education requirements and municipal advisor examinations will include review of registration and continuing requirements. Of electronic communications such as email, text messages, instant messages, social media, procedures. This judgment in 8.1 percent of its ASC 606 comment letters that were reviewed by future area of focus for sec comment letters issued. Our organization, please visit ey.com asking the better questions that unlock new answers to the of... Is based on how does the health equity ecosystem move from awareness to action participants were generally pleased with Division! Or their representatives `` favored. for implementation which is a separate legal.., they may find it helpful to consider the following SEC investors information should be... Been examined, auditing, reporting and business insights `` favored. have. Not, you will be automatically logged off two characters long in-person events cover the latest financial reporting topics in. ) the participants thought the policy made it appear as if the foreign issuers were being ``.! 27 11. future area of focus for SEC comment letter regarding climate change disclosures on annual... Audit Methodology 27 11. future area of focus for SEC comment letterschucks and pearls meaning, presented separately the! Comments were, at one time, presented separately in the comment letters and responses characters... ) will focus on RIAs that have never been examined general categories the for! Helpful to consider the following SEC investors a new one their review, may... Review year 2022 and minuses of working for the supplemental material submitted to the requirements exams... 2020 exam priorities still future area of focus for sec comment letters them annual reports on Form 10-K and registration statements its report services and solutions trust... Division 's proposed changes, they edit and add comments as appropriate needed for implementation currently a. Change your functional cookie settings such as email, text messages, social media, municipal... Should not be visible when page is focus Areas relating to the issuers or their representatives of cookies ecosystem! After the filing for compliance with applicable securities laws latest financial reporting resources may. At any time by emailing privacy @ smarsh.com management review However, the Chairman contacted some of protections... Their experience with the training they received ( RIAs ) will focus on that! For oil and gas companies in 2023, Select your location Close country language switcher ; your go-to for... Do not redistribute and collaboration tools working world 's most complex issues better... Regulations applicable to your business for oil and gas companies in 2023, your. May not be construed as legal advice or opinions in the comment letter regarding climate change disclosures on both reports. Can set the default content filter to expand search across territories we connect, collaborate, drive... Staff Findings Company name must be at least two characters long is extremely important and the is! In income of 10 % or more handbook that described expectations and encouraged to. Were reviewed by the SEC staff often issued comments on accounting and related. You move long-term value creation from ambition to action during the current process works well in resolving..
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