SEC now: MD&A 2025 comment letter trends

We continue our SEC-focused series with a discussion of management’s discussion and analysis (MD&A), a topic that remains a consistent focus in SEC staff comment letters. In this episode, we explore the latest trends, common themes, and areas of emphasis—including results of operations, liquidity, and critical accounting estimates—and share practical considerations as companies prepare year-end filings.

In this episode, we discuss:

• 1:31 – An overview of SEC comment letter trends related to MD&A
• 6:43 – The results of operations
• 25:16 – Liquidity and capital resources
• 28:30 – Critical accounting estimates
• 35:24 – Final reminders and best practices related to MD&A

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

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

For more on the SEC, listen to our recent episodes:

• Key takeaways from the AICPA & CIMA Conference
• SEC to revisit quarterly reporting: Pros, cons, and what’s ahead

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About our guests

Lindsay McCord is a PwC National Office partner specializing in matters related to the SEC and the capital markets. Prior to joining PwC, Lindsay spent over 15 years at the SEC, most recently as the Chief Accountant in the Division of Corporation Finance. In this role, Lindsay led an accounting team in providing technical accounting and reporting support to the Division, including SEC rulemaking, interpretation, and guidance.

Ryan Spencer is a partner at PwC's National Office specializing in SEC reporting matters both for US domestic issuers and some of the world’s largest foreign SEC registrants. He has over 25 years of experience serving clients and is a frequent contributor to PwC’s publications.

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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