2024 SEC comment letter trends: Revenue

PwC's accounting podcast

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In this next episode of our 2024 SEC comment letter miniseries, we discuss accounting for revenue. Revenue is the top line for a reason; it’s closely watched by investors and therefore, the SEC staff as well. From variable consideration to disaggregated revenue disclosure, 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:

• 2:25 – An overview of SEC comment letter trends related to revenue
• 12:20 – Significant judgements and estimates in determining the transaction price
• 23:57 – Timing or pattern of the transfer of control
• 28:10 – Disaggregated revenue disclosures
• 40:45 – Other reminders and areas of focus related to revenue
• 44:22 – Industry-specific considerations

For more information, see our full analysis of SEC comment letter trends, our Revenue from contracts with customers guide, and Chapter 33 of our Financial statement presentation guide.
Also, check out our other episode in this miniseries, SEC comment letters – What’s trending in 2024. Additionally, follow this podcast on your favorite podcast app for more episodes.
Pat Durbin is a Deputy Chief Accountant in PwC’s National Office. He has over 30 years of experience consulting with our clients and engagement teams on complex accounting matters, including issues related to revenue, compensation, income taxes, and inventory under both US GAAP and IFRS.
Mike Coleman is a partner in PwC's National Office who 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.
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.
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Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [e-mail].

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1. 2024 SEC comment letter trends: Revenue (00:00:00)

2. An overview of SEC comment letter trends related to revenue (00:02:25)

3. Significant judgements and estimates in determining the transaction price (00:12:20)

4. Timing or pattern of the transfer of control (00:23:57)

5. Disaggregated revenue disclosures (00:28:10)

6. Other reminders and areas of focus related to revenue (00:40:45)

7. Industry-specific considerations (00:44:22)