SEC now: Segments 2025 comment letter trends

We continue our SEC-focused series with a discussion of segment disclosures, reporting trends, and early comment letter themes emerging from the adoption of the new standard. In this episode, we explore common staff observations, including the role of the Chief Operating Decision Maker, or CODM; significant expense disclosures; and interplay with non-GAAP measures.

In this episode, we discuss:

• 1:46 – Why segment disclosures remain a top SEC focus
• 8:04 – Early comment themes under the new standard
• 15:14 – Multiple profit measures and non-GAAP considerations
• 28:14 – How the SEC evaluates a company’s segment structure
• 35:28 – Ongoing reassessment of impacts to segments

In case you missed it, check out the previous episodes in this SEC-focused series:

• SEC now: 2025 comment letter trends on transactions
• SEC now: Non-GAAP 2025 comment letter trends
• SEC now: Today’s landscape and recent developments

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About our guests

Kevin Vaughn is a PwC National Office partner specializing in SEC reporting matters. Kevin leverages his extensive experience to support PwC public company and pre-IPO clients on accounting and SEC reporting matters. Prior to joining PwC in 2023, Kevin spent over 18 years at the SEC, most recently serving on the leadership team in the SEC’s Office of the Chief Accountant where he focused on technical accounting consultations, SEC rulemakings, and standard setting matters.

Jay Seliber is a partner in PwC’s National Office. He leverages over 35 years of experience to help clients with their most complex accounting matters, particularly in the areas of mergers and acquisitions, segment reporting, revenue recognition, stock compensation, earnings per share, employee benefits, restructurings, impairments, and financing transactions.

About our guest host

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.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com 

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