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On September 22, 2021, CorpFin staff posted this “Sample Letter to Companies” to provide example climate change disclosure comments.  These Sample Letters, which are a successor to older “Dear CFO” letters, provide illustrative comments about emerging and “hot-button”
Continue Reading CorpFin Issues Sample Letter to Companies With Climate Change Comments

In this post from June 28, 2021, we reviewed an SEC enforcement action focused on the relationship between cybersecurity risks and disclosure controls and procedures.  This relationship was emphasized in the SEC’s February 26, 2018 Release, Commission Statement and
Continue Reading Yet Another Cybersecurity and Disclosure Controls and Procedures Enforcement

In this Form 10-Q for the quarter-ended May 31, 2021, Pure Cycle reflected a “little-r” prior-period adjustment related to public improvement reimbursables and related interest.  The Form 10-Q includes this footnote
The Company discovered certain errors in the amounts
Continue Reading A “Little-r” Adjustment – Spreadsheet Complications and Disclosure Control Reporting