Revenue: 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.

This week, Heather Horn sat down with Angela Fergason, a partner in PwC’s National Office, who shared her insights on the comments on the top line of the income statement, revenue, from the SEC staff to registrants this year.

In this episode you’ll hear discussion of:

• 1:24 - Trends noted in the volume and type of comments on revenue
• 6:04 - The increased focus on judgments made in disaggregated revenue disclosures
• 10:25 - Presentation of revenue and cost of revenue in the income statement 
• 15:52 - The continued SEC staff focus on gross vs. net presentation and identification of performance obligations
• 19:52 - Comments on common industry-specific revenue arrangements 
• 22:54 - Angela’s advice for listeners when looking ahead to year-end

Want to learn more? Check out our analysis of SEC comment letter trends and stay tuned for more episodes in the series. We also have episodes specific to revenue, such as our revenue toolkit podcast miniseries that goes step by step through the revenue recognition model.

Angela Fergason is a partner in PwC's National Office with over 20 years of experience who specializes in accounting for revenue and employee compensation arrangements. She also consults on a range of financial reporting issues impacting technology companies. Angela is a frequent speaker on accounting and financial reporting topics and is a contributor to many PwC National Office publications, including our accounting guides on revenue and stock-based compensation.

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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