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SEC Disclosure Priorities for 2024

In his State of Disclosure Review, U.S. Securities and Exchange Commission Director of Corporation Finance Erik Gerding provided an overview of the annual report review program and outlined disclosure priorities for 2024. 

Gerding reported that the top areas of comment in fiscal year 2023 were:

  • China-related matters
  • Non-generally accepted accounting principles (GAAP) disclosures
  • Management discussion and analysis (MD&A)
  • Revenue recognition
  • Financial statement presentation

He also outlined the following disclosure priorities for fiscal year 2024:

  • Artificial intelligence
  • Disclosures by China-based companies
  • Commercial real estate, including, among others, risks related to heightened vacancy rates, elevated interest rates, extended loan maturities, and increased loan delinquencies
  • Cybersecurity
  • Clawbacks
  • Pay versus performance
  • Universal proxy
  • Beneficial ownership reporting
  • Inflation 
  • Market disruptions in the bank industry, including interest rate risk and liquidity risk
  • Financial reporting topics, including segment reporting, non-GAAP, critical accounting estimates disclosure in MD&A, and disclosure regarding supplier finance programs in the notes to financial statements and MD&A. 


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