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This week we kicked off our 2023 SEC comment letter trends podcast series. With nearly 1,350 comments issued by the SEC staff to public companies this year, we share insights on the staff’s top areas of focus to get you ready for year-end reporting.
And, subscriber note, before disconnecting for next week’s holiday, there will be a new (albeit abbreviated) weekly newsletter delivered to your inbox next Wednesday.
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 staff in the SEC’s Division of Corporation Finance.
This week, host Heather Horn was joined by Kyle Moffatt, PwC National Office Professional Practice Leader, to share an overview of the 2023 comment letter trends, a breakdown of the review process, and insights into the SEC staff’s key priorities. And, to see Kyle and Heather test their knowledge listing the top comment letter trends, watch the series’ kickoff video.
Want to learn more? Check out our full analysis of SEC comment letter trends.

Investors want to better understand how companies are managing crises and staying resilient, while creating and protecting long-term value in today’s fracturing world. They are looking closely at two areas — emerging technology and sustainability — to gauge whether companies can seize opportunities for reinvention and business transformation, or will instead succumb to rivals.
Our third annual Global Investor Survey report compiles perspectives from 345 investors and analysts across geographies, asset classes, and investment approaches — and provides insights into the factors that most affect the companies they invest in and cover. Some key takeaways include: prioritizing new and emerging technologies, embedding sustainability to drive value, and addressing the reporting trust deficit. Read the full report for more.

Sustainability reporting corner
  • Audio: California’s not waiting for the SEC’s climate disclosure rules
    As we shared last week, we updated our publication on the climate disclosure laws that are poised to change the landscape of climate reporting in the United States. This week, we share the updated audio version, or you can read the publication.
  • Updated: Worldwide impact of CSRD - are you ready?
    This In the loop was updated to reflect recent developments, including the end of the scrutiny period of the European Sustainability Reporting Standards and recent activity at the European Commission, and to add additional content on noncompliance and materiality assessments.
  • CSRD spotlight: Hot topics in the EU's green taxonomy
    Continuing our CSRD podcast miniseries, we dive deeper into the topic we covered last week, the EU’s green taxonomy regulation, which requires disclosure of certain metrics related to a company’s environmentally sustainable activities as early as 2024. In this episode, host Heather Horn welcomes back PwC Germany senior manager Martin Schönberger to address common questions related to interpretation of the rules, eligibility of the activities, and calculation of the metrics as they apply to non-financial services companies.
    "Taxonomy disclosures will require a constant updating process; it is not something that you do once and then you're set for the next 20 years. It will require the attention of the company to ensure disclosures remain relevant and accurate." - Martin Schönberger, PwC Germany

PwC’s CPE-eligible webcasts
Register for our year-end accounting webcasts for both US GAAP and IFRS reporters.
  • Q4 2023 Quarterly accounting webcast—12/13, 12/15, or 12/19
    Join our quarterly webcast to hear key accounting and reporting reminders, including those discussed at the AICPA & CIMA Conference on Current SEC and PCAOB Developments, as companies close out the year. Register to earn up to 1.5 CPE credits.
  • IFRS year-end accounting webcast—1/18
    Join PwC’s year-end accounting and reporting webcast for IFRS reporters. Our team of IFRS specialists will address year-end accounting and reporting reminders and recent activities. We’ll also let you know what to expect in IFRS reporting in 2024. Register to earn up to 1 CPE credit.
Need CPE credits? Visit our Accounting and reporting webcasts page on Viewpoint to view our full library.

Finance transformation: four areas of focus for the audit committee
Across sectors and industries, corporate finance functions are transforming to become more agile, efficient, and technology-focused. We share four focus areas to consider as you work with audit committees and the finance function continues to evolve.
Here’s what we’re following
SEC announces fiscal year 2023 enforcement results
This week, the SEC announced enforcement results for its fiscal year ending September 30, 2023. The SEC obtained orders for nearly $5 billion in financial remedies for the year, the second highest ever. Of the 784 enforcement actions filed, approximately 83% were against corporations and 17% were against individuals, collectively including a variety of market participants from large public companies and investment firms to gatekeepers and social media influencers.
The SEC’s actions spanned a range of topics including frauds against retail investors, abusive trading practices, misconduct related to crypto asset securities, misleading or omitted disclosures of cybersecurity risks and incidents, and ESG-related cases.

Update: Members of Congress send letter to prudential regulators on SAB 121
This week, a group of lawmakers urged the Office of the Comptroller of the Currency, the Federal Reserve Board of Governors, the Federal Deposit Insurance Corporation, and the National Credit Union Administration to clarify “through guidance or other action” that SEC Staff Accounting Bulletin 121 (SAB 121) is not enforceable considering the Government Accountability Office’s (GAO) finding that it constitutes a “rule” for purposes of the Congressional Review Act.
SAB 121 was issued by the staff in the Division of Corporation Finance and the Office of the Chief Accountant to address the accounting by entities that have an obligation to safeguard crypto assets that an entity holds for platform users.
As we shared in the November 3rd edition, the GAO concluded that SAB 121 should have been subject to a 60-day period during which Congress could have disapproved the rule. However, until further actions are taken the guidance in SAB 121 remains applicable.
For more on SAB 121, read our summary, Perspectives on SAB 121 and safeguarding crypto assets.

New and reappointed FASB and GASB board members, new PCC member
The Financial Accounting Foundation (FAF) announced various appointments to the FASB and GASB.
  • Susan Cosper has been reappointed for a second, five-year term as a FASB board member beginning July 2024.
  • Hillary Salo has been appointed as a FASB board member beginning July 2024 (succeeding James Kroeker).
  • Carolyn Smith has been reappointed for a second, five-year term as a GASB board member.
In addition, David Finkelstein has been appointed as a Private Company Council (PCC) member beginning in January 2024.

Key dates
November 30
Tax transparency and sustainability reporting in 2023 webcast
Register here
December 1
Deadline to comment on the International Auditing and Assurance Standards Board’s International Standard on Sustainability Assurance (ISSA) 5000, General Requirements for Sustainability Assurance Engagements
December 13, 15, or 19
Q4 2023 Quarterly accounting webcast (CPE eligible)
Register here
December 13
Public roundtable on FASB’s proposed Accounting Standards Update, Disaggregation of Income Statement Expenses
Register here
December 14
Year-end audit committee webcast (CPE eligible)
Register here
December 14
Health industries accounting hot topics webcast (CPE eligible)
Register here
January 18
IFRS year-end accounting webcast (CPE eligible)
Register here
February 15 or March 5
Q1 2024 Quarterly sustainability webcast (CPE eligible)
Register here
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