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SEC Reporting Update - Highlights of trends in 2025 SEC staff comment letters


Overview

Our SEC Reporting Update publication discusses the comment letters issued by the SEC staff during the year ended 30 June 2025. The number of letters fell compared to the previous two years, bringing the volume of letters closer to that of 2022. Management’s discussion and analysis and non-GAAP financial measures remained at the top of the list of topics most frequently addressed by the SEC staff, followed by segment reporting, revenue recognition and goodwill and intangible assets. The publication also highlights areas where the SEC staff may focus in the future and provides considerations for navigating the comment letter process.

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