This next episode of our 2024 SEC comment letter podcast miniseries discusses Foreign Private Issuers (FPIs). Many of the considerations we talk about for other SEC filers also apply to FPIs; however, there can be some differences and added complexities. We discuss the issues most frequently raised by the SEC staff, including those unique to FPIs, and offer advice to preparers for getting ahead of them. 

In this episode, we discuss:

• 7:24 – Comment letter trends specific to FPIs, including those related to: 
  • 8:55 – Non-GAAP performance measures
  • 16:15 – Segment reporting
  • 21:32 – Revenue
  • 25:01 – Management’s Discussion and Analysis
  • 30:29 – Financial instruments
• 41:39 – FPI status re-assessment
• 44:53 – IFRS segment reporting considerations  
• 47:45 – Other accounting and reporting reminders related to FPIs

For more information, see our full analysis of SEC comment letter trends. 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
• 2024 SEC comment letter trends: Segment reporting
• 2024 SEC comment letter trends: MD&A

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

Patrick Higgins is a Deputy Chief Accountant in PwC’s National Office responsible for our SEC foreign private issuer and IFRS teams. Patrick has also served as a global signing partner in a variety of countries and industries.   

Kevin Vaughn is a PwC National Office partner specializing in SEC reporting matters. Kevin leverages his extensive experience to support PwC public company and pre-IPO clients on accounting and SEC reporting matters. Prior to joining PwC in 2023, Kevin spent over 18 years at the SEC, most recently serving on the leadership team in the SEC’s Office of the Chief Accountant where he focused on technical accounting consultations, SEC rulemakings, and standard setting matters.

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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