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2024 SEC comment letter trends: Segment reporting


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This next episode of our 2024 SEC comment letter podcast miniseries discusses segment reporting.  

Segment reporting is an important disclosure for investors as it provides information about the different types of business activities in which a reporting entity engages and the different economic environments in which it operates – making this an area that frequently gets the attention of the SEC staff. We discuss the issues most frequently raised by the SEC staff and offer advice to preparers for getting ahead of them. 

In this episode, we discuss: 

  • 2:36 – An overview of SEC comment letter trends related to segment reporting
  • 11:49 – Identifying operating segments
  • 15:13 – Aggregation of operating segments 
  • 16:36 – Entity-wide segment disclosures 
  • 19:18 – Multiple measures of segment profit or loss
  • 20:55 – Reconciliations to segment profit or loss 
  • 23:18 – Considerations when adopting the FASB’s new segment reporting guidance
  • 35:21 – Final reminders related to segment reporting 

For more information, see our full analysis of SEC comment letter trends and Chapter 25 of our Financial statement presentation guide. Also, check out our other episodes in this miniseries:  

  • SEC comment letters – What’s trending in 2024  
  • 2024 SEC comment letter trends: Revenue
  • 2024 SEC comment letter trends: Business combinations 

Additionally, follow this podcast on your favorite podcast app for more episodes.

Scott Feely is a partner in PwC’s National office.  He has over 30 years of experience supporting clients as they address the SEC and financial reporting implications of their capital markets and merger and acquisition-related activities.

Jay Seliber is a partner in PwC’s National office. He leverages over 30 years of experience to help clients with their most complex accounting matters, particularly in the areas of mergers and acquisitions, revenue recognition, stock compensation, earnings per share, employee benefits, restructurings, impairments, and financing transactions.

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance. 

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [email protected]. 

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