MD&A: 2022 SEC comment letter trends

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In each episode of our 2022 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance.

Kyle Moffatt, PwC National Office partner, is back in the guest seat with our host, Heather Horn, to share key insights on the #1 top SEC comment letter trend in 2022, MD&A.  

In this episode you’ll hear discussion of:

• 1:27 - The impact of changes to MD&A guidance 
• 8:01 - The types of MD&A comments registrants are receiving
• 11:45 - Who should be involved in telling a company’s story in MD&A
• 14:56 - How the SEC's priorities influence comments in this area 
• 19:41 - The importance of company compliance with the overarching principles of MD&A
• 24:20 - How emerging trends are impacting comment letters 
• 33:12 - Advice for companies as they prepare their year-end filings

Want to learn more? Check out our analysis of SEC comment letter trends and stay tuned for more episodes in the series. For more information on the SEC’s disclosure requirements pertaining to MD&A, check out our In depth on the amended rules and Topic 9 of the SEC’s Financial Reporting Manual.

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.

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.

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