Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 05 SEPTEMBER 2019

Early Look At First Batch Of CAMs Disclosures

WilmerHale
WilmerHale
Contributor
WilmerHale

WilmerHale

WilmerHale's London office was established more than 40 years ago. With lawyers qualified in the...

View firm profile
Explore more from WilmerHale

More than two years since the PCAOB adopted the new critical audit matters (CAMs) disclosure requirement

United StatesAccounting and Audit
Alan Wilson
Alan Wilson
Author LinkedIn connections

More than two years since the PCAOB adopted the new critical audit matters (CAMs) disclosure requirement, the first batch of CAMs disclosures is finally rolling out with respect to audits of large accelerated filers with fiscal years ending on or after June 30, 2019.  The much anticipated disclosures, in many respects, hew relatively closely to the expectations established by the Public Company Accounting Oversight Board in the guidance it provided in the months leading up to the first effective date of the new standard.  

Some early observations based on a sampling of CAMs disclosures provided by five audit firms covering 18 large accelerated filers are as follows:

  • Number of CAMs.  The average number of separate CAMs disclosures per sampled company was two, ranging from one to three per company.  

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Staff Statement On Fair Value Measurement And Disclosure Considerations For Private Assets

The SEC Staff has issued new guidance addressing fair value measurement and disclosure practices for private credit and other illiquid assets held by registered funds and business development companies. As private credit portfolios have grown nearly 60% since 2020, reaching $270 billion, regulators emphasize the critical importance of robust valuation methodologies, transparent disclosure of significant judgments, and careful application of accounting standards when market prices are unavailable.
United StatesAccounting and Audit
Mayer Brown
Mayer Brown
Article

FASB Proposes New Guidance On Stablecoin Classification As Cash Equivalents And Enhanced Disclosure Requirements

On August 18, 2026, the Financial Accounting Standards Board (“FASB”) issued a proposed accounting standards update (“ASU”) titled Statement of Cash Flows (Topic 230): Cash Equivalents—Disclosure Enhancement and Evaluation of Certain Digital Assets. The proposed ASU seeks to clarify whether certain digital assets meet the definition of “cash equivalents” on the balance sheet, and to increase the transparency of the significant components of “cash equivalents.”
United StatesAccounting and Audit
Mayer Brown
Mayer Brown
Article

CAS Board Raises Contract Thresholds To $35 Million And Eliminates CAS 407: What Federal Contractors Need To Know As DoW Demands Cost And Pricing Transparency

The CAS Board has raised contract thresholds to $35 million and eliminated CAS 407, fundamentally changing cost accounting requirements for federal contractors. At the same time, the Department of War is demanding unprecedented cost and pricing transparency through new memoranda requiring actual cost information for negotiations valued at $10 million or more, creating a complex landscape where contractors face fewer formal CAS requirements but heightened scrutiny of their pricing data.
United StatesAccounting and Audit
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

2026 GAAP Changes: What Your Finance Team Should Address Before Year-End

Finance teams face critical implementation challenges as new GAAP amendments take effect for 2026, requiring immediate attention to accounting policies, documentation standards, and system readiness. Are your financial reporting processes prepared to handle expanded disclosure requirements, CECL practical expedients, and internal-use software accounting changes before year-end audit fieldwork begins?
United StatesAccounting and Audit
MGO CPA LLP
MGO CPA LLP
Article

How OIG Used Data Analytics And Extrapolation In A $12.4 Million Hospital Audit

An HHS Office of Inspector General audit of Methodist Hospital in San Antonio reveals how a review of just 100 claims led to a $12.4 million overpayment recommendation through statistical extrapolation. The audit targeted specific high-risk billing areas including Inpatient Rehabilitation Facility claims, certain diagnosis-related groups, and outpatient billing patterns, uncovering documentation and coding compliance issues that hospital leadership should examine within their own Medicare claims.
United StatesAccounting and Audit
Butler Snow LLP
Butler Snow LLP
Article

PTAB/USPTO Update - October 2026

The USPTO has released new templates and guidance for AIA trial proceedings, announced key appointments including a Chief AI Officer, and published updated procedures for patent applications and subject matter eligibility declarations. Director Squires delivered multiple addresses emphasizing the constitutional importance of intellectual property rights while the agency expanded its community engagement efforts and international collaboration through WIPO's Global IP Assignment Platform pilot program.
United StatesIntellectual Property
WilmerHale
WilmerHale
Article

23x5 Trading Comes To US Exchanges: What Firms Should Know Before Launch

US national securities exchanges are preparing to launch 23x5 trading by December 6, 2026, marking the most significant expansion of trading hours in decades. This comprehensive analysis examines the regulatory approvals, operational infrastructure changes, investor protection mechanisms, and issuer considerations necessary to support overnight equity trading from Sunday through Thursday evenings.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

SEC Approves FINRA’s New “Outside Activities” Rule

The Securities and Exchange Commission has approved FINRA Rule 3290, which will replace existing rules governing outside business activities and private securities transactions for registered persons. This new rule narrows the scope to focus on investment-related activities while maintaining similar supervisory obligations for member firms. Understanding the key changes and implementation requirements will be critical for broker-dealers as they update their compliance policies and procedures.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

Lame Duck, High Stakes: Congress’s Postelection Agenda

As Congress prepares for its postelection lame-duck session, lawmakers face critical decisions on government funding, defense authorization, and potential debt-limit increases. The election outcome will determine whether Republicans push through major legislation before potentially surrendering control, or whether both parties defer negotiations into 2027. With permitting reform, tax extenders, and reconciliation packages on the table...
United StatesGovernment, Public Sector
WilmerHale
WilmerHale
Article

California Adopts Law To Impose New Guardrails On Attorneys And Arbitrators Use Of AI

California's new SB 574 establishes the first statutory framework governing attorneys' and arbitrators' use of generative artificial intelligence, imposing verification requirements and disclosure obligations that take effect in January 2027. The law responds to recent court sanctions for AI hallucinations while leaving unresolved critical questions about privilege, work-product protection, and the boundaries between permissible assistance and impermissible delegation.
United StatesCorporate/Commercial Law
WilmerHale
WilmerHale
Article

Section 232 Pharmaceutical Tariffs Are Now In Effect: It’s Not Too Late To Consider Duty-Mitigation Strategies

On September 29, 2026, the final phase of Section 232 pharmaceutical tariffs took effect, imposing an additional 100 percent ad valorem duty on many imported patented pharmaceuticals and ingredients. While these duties may substantially increase import costs, several customs and trade mechanisms may be available to reduce, eliminate, or defer the tariffs.
GlobalInternational Law
WilmerHale
WilmerHale
Article

SEC 2027 Exam Priorities: Familiar Priorities, Evolving Markets

The SEC Division of Examinations has released its fiscal year 2027 examination priorities, signaling continued focus on investment adviser fiduciary obligations, broker-dealer financial responsibility, and Regulation Best Interest while adapting to evolving market practices. Private credit, artificial intelligence governance, and retail investor protection emerge as prominent areas of scrutiny, with examiners expected to probe valuation practices, conflicts of interest, and technology controls across regula
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

The SEC’s Transfer Agent Modernization Proposal: Implications For Onchain Recordkeeping

The SEC has proposed a comprehensive overhaul of transfer agent regulations that would formally recognize distributed ledger technology and blockchain-based recordkeeping systems within the existing regulatory framework. This modernization effort imposes enhanced operational, safeguarding, and compliance obligations while establishing technology-neutral standards that could significantly impact tokenization initiatives and digital asset market infrastructure.
United StatesFinance and Banking
WilmerHale
WilmerHale