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Overview
Our SEC Reporting Update publication discusses the comment letters issued by the SEC staff during the year ended 30 June 2024. The number of letters was consistent with last year when it was sharply higher compared with each of the previous four years. Management’s discussion and analysis and non-GAAP financial measures remained in the top two spots on the list of the most frequent topics the SEC staff addressed in comment letters, followed by segment reporting, revenue recognition, goodwill and intangible assets, and business combinations. The publication also highlights areas where the SEC staff may focus in the future and provides considerations for navigating the comment letter process.