2013 SEC Comment Letter Trends

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It is always interesting to gain feedback on the kinds of comments the SEC gives on various filings, particularly IPO S-1s and 10-Ks.  Here is a brief but interesting analysis, in case you missed it, from my PwC.  As you can see, most of the comments go to valuation, which is more of a pre-IPO grant issue, but a highlighted comment emphasizes the SEC’s ongoing interest in comp plan process integrity–notice the inquiry related to peer group identity.

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