Most often, I was the only person that made up the SEC reporting team. I did a complete tie-out of the entire document (10-Q/10-K/8-K) and it was reviewed by my direct supervisor (Controller, VP of Accounting, etc.). Currently, the entire tie-out is prepared using Wdesk and it is sent to our auditors in pdf format. It is working quite well! I would think you'd have an internal control process around the tie-out and review?
Original Message:
Sent: 12-08-2023 12:31 PM
From: Jamie Yamamoto
Subject: Tie out responsibilities
Thanks for the insight Steve! This is what I wanted to get a pulse on. With smaller SEC reporting teams (i.e. team of one) I was curious how the they tie out assignments were spread out to the accounting team and at what level.
Interesting note on the reduction in fees by bringing in the auditor. I've tried to pull them in for draft review and comments, and they were going to INCREASE our billing. But perhaps the tie out documentation might have been a better selling point. I'll keep this one in mind for the future.
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Jamie Yamamoto
Director of SEC Reporting and Technical Accounting
Sterling Check Corp.
Original Message:
Sent: 12-07-2023 08:16 PM
From: Steve Soter
Subject: Tie out responsibilities
Thanks for the great questions Jamie! If I remember correctly, our last survey of SEC Pro members told us that the average team size was about 3-5 people. That's a bit subjective, however, considering that many teams will use dual-purpose roles to help with SEC reporting at quarter-end, and then focus on non-financial reporting projects when they weren't preparing a filing. When I was running SEC reporting teams, we had our SEC Staff preparing the tie outs (with clerical assistance from an intern), which would get reviewed by a manager, myself (as the director), and then by our controller (only for selected areas of the document) before being delivered to the external auditors. We also did our tie-outs in Workiva, so all of the review occured digitally, even our external auditors.
(Initially our auditors refused to go in to Workiva but we insisted. After a couple of years, we actually negotiated a reduction in audit fees based on the efficiency gains that the digital review created for them.)
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Steve Soter
Executive Advisor
SEC. ESG & SOX Pro Groups
Original Message:
Sent: 12-04-2023 04:14 PM
From: Jamie Yamamoto
Subject: Tie out responsibilities
Hi SEC preparers,
I'm looking to benchmark how companies handle their tie out process. If you have any best practices or advice that has worked well, please share.
1. Who prepares and who reviews your 10-Q and 10-K tie outs? (i.e. prepared by SEC Staff, Accounting Senior, and reviewed by SEC Manager, Controller, etc.
2. Can you provide the approximate size of your SEC Reporting team?
Thanks in advance!
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Jamie Yamamoto
Director of SEC Reporting and Technical Accounting
Sterling Check Corp.
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