To kick off our 2022 SEC comment letter series, we sat down with Kyle Moffatt, a partner in PwC's National Office, to provide an overview of the trends.
In each episode of our What’s trending in SEC comments series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance for the most common topical areas of the financial statements.
To kick off the series, this week Heather Horn sat down with Kyle Moffatt, a partner in PwC’s National Office, to provide an overview of the 2022 comment letter trends, insights into the key priorities of the SEC, and what we can expect to see in the future based on the SEC’s agenda.
In this episode you’ll hear discussion of:
  • 1:41 - The SEC’s priorities and how they influence comment letters
  • 10:38 - The top comment letter trends in 2022
  • 16:03 - How companies should consider “Dear Issuer” letters in their year-end reporting
  • 23:13 - The SEC staff’s approach to comment letters and what we expect in the near future
  • 28:06 - The SEC staff’s comments in proxy statements
  • 30:49 - Kyle’s advice for SEC registrants on what to do if they receive a comment letter
Want to learn more? Check out our analysis of SEC comment letter trends and stay tuned for more episodes in the series.
About our guest
Kyle Moffatt is a partner in PwC's National Office where he 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.
About our host
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
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