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In each episode of our 2023 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance.

This week, host Heather Horn sat down with PwC National Office partner Mike Coleman to discuss common issues noted in the SEC staff’s comments on revenue, and why it consistently remains a top area of focus.

In this episode, you’ll hear:

• 2:03 - An overview of comment letter themes related to revenue and a discussion of the prominence of revenue in financial reporting
• 6:53 - Key considerations in determining performance obligations and the significance of judgments made
• 14:19 - Insights on the continued focus on revenue estimates, including challenges related to recognizing variable consideration and determining standalone selling prices when estimates are embedded in transaction prices
• 20:46 - Common pitfalls with revenue disclosures
• 27:26 - Important reminders on principal-versus-agent considerations
• 30:54 - Sector-specific insights and trends and the value in competitor benchmarking 
• 35:48 - Best practices for preparers on avoiding or responding to SEC staff comments on revenue

Want to learn more? Check out our analysis of SEC comments on revenue, as well as our Revenue guide. Also, listen to a previous podcast on trends in revenue more broadly and read our guide on accounting for revenue.  

Mike Coleman is a partner in PwC's National Office with over 30 years of experience. Mike specializes in accounting for revenue and software arrangements and has served technology clients for much of his career. In addition, Mike has represented the firm on the AICPA Software Task Force.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Follow PwC’s accounting podcast on your favorite podcast app for future episodes in this SEC comment letter series, and subscribe to our weekly newsletter to get all of our thought leadership.

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