The SEC's Division of Corporation Finance recently posted a
set of slides addressing common financial reporting issues for
smaller issuers. The slides were part of a presentation for a small
business forum hosted by the PCAOB in December 2011 and, broadly
speaking, summarize observations of the SEC staff (the Staff) on
particular topics that arise frequently in the SEC's review of
smaller companies. The slides are noteworthy because the Staff does
not frequently assemble such a fulsome set of examples and
guidance. The presentation is available at: http://www.sec.gov/news/speech/2012/
spch020912co.pdf .
The slides provide background for the Staff's authority to
conduct reviews and give some insight into the current areas of
focus. The Staff has revised its review process, particularly with
respect to smaller companies, and will no longer use formal
categories, such as limited reviews and full reviews. Instead, the
Staff will focus its attention on companies as