Data-quality corner: highlights from SEC comment letters
Among the range of resources available to filers with the US Securities and Exchange Commission (SEC) EDGAR system, comment letters are sometimes overlooked. These are sent by the Division of Corporate Finance to public companies where it finds room for improvement in their disclosures.
Companies are required to reply to each item in a responding comment letter, and amend their filings if needed.
While these letters are addressed to individual companies, they are of potential interest to anyone involved in business reporting in the US – or indeed more widely. Alongside other types of reporting concerns, some letters point out tagging errors and other digital pitfalls, and the kinds of simple fixes that can make big improvements in data quality. This month, we’ll be highlighting a few SEC comment letters from recent years that are worth looking back at.
We begin in January this year, with a comment letter from the SEC to RH. This instructed the filer to revise its XBRL definition of income before equity method Investments, utilising the correct definition to accurately reflect its treatment of income (loss) from equity method investments. While this might superficially appear to be a relatively trivial point, it is the kind of error that hinders effective analysis and data comparability down the line – a reminder of the importance of careful attention to definitions.
Read the SEC comment letter here, or investigate all past letters and related filings using the EDGAR search tool and selecting ‘Filing review correspondence’ under ‘Filing category’ in ‘more search options.’