Securities & Asset Management
4 SEC staff comments and 15 disclosure examples from companies in this industry.
SIC codes included: 6211 Security Brokers, Dealers & Flotation Companies, 6282 Investment Advice, 6200 Security & Commodity Brokers, Dealers, Exchanges & Services, 6221 Commodity Contracts Brokers & Dealers
Disclosure examples by topic
Securities & Asset Management: Fair value: Level 3 measurements3 examplesSecurities & Asset Management: Subsequent events (ASC 855)3 examplesSecurities & Asset Management: Credit losses (CECL, ASC 326)2 examplesSecurities & Asset Management: Non-GAAP measures in MD&A1 exampleSecurities & Asset Management: Cybersecurity (Item 1C)1 exampleSecurities & Asset Management: Earnings per share (ASC 260)1 exampleSecurities & Asset Management: Pay versus performance1 exampleSecurities & Asset Management: Crypto assets (ASU 2023-08)1 exampleSecurities & Asset Management: Debt & covenant compliance1 exampleSecurities & Asset Management: Related party transactions (ASC 850)1 example
What the SEC staff asked companies in this industry
Non-GAAP: Reconciliation & Usefulness (3)Non-GAAP: Adjustments & Labels (2)Business Description (Item 101) (1)Goodwill & Asset Impairment (1)Fair Value & Investments (1)KPIs, Metrics & Earnings Calls (1)
Waton Financial Ltd (WTF) · 2026-03-24 · Waton Financial Limited Form 20-F for Fiscal Year Ended March 31, 2025 · Comment 1 · B. Business Overview, page 44 Agreed to revise
Staff comment: We note your disclosure of the non-GAAP financial measures 'Adjusted Net Income' and 'Adjusted Net Loss' in your business overview on page 45 when discussing results of operations in the periods presented. Please represent to us that, in future filings, you will provide all the non-GAAP disclosures required by Item 10(e)(1)(i) of Regulation S-K. letter →
Company response: The Company acknowledges the Staff’s comment. In future filings, the Company will provide all of the disclosures required by Item 10(e)(1)(i) of Regulation S-K with respect to any non-GAAP financial measures presented. response letter →
Waton Financial Ltd (WTF) · 2026-03-24 · Waton Financial Limited Form 20-F for Fiscal Year Ended March 31, 2025 · Comment 2 · (n) Investment, cost, page F-11 Agreed to revise
Staff comment: We note that you assess impairment of your equity investment without a readily determinable fair value using an other-than-temporary model. We also note that ASU 2016-01 removed this model for these equity security investments to apply a one-step approach as explained further in paragraphs BC85 to BC89 of that ASU. As a result, please address the following: • Tell us whether your $618,630 impairment recorded in fiscal 2025 would have been larger or whether you would have recorded any impairment in fiscal 2024 if, instead of apply an other-than-temporary model, you employed a direct assessment of fair value to carrying value if indicators of impairment existed. If so, demonstrate to us… letter →
Company response: The Company acknowledges the Staff’s comment. The Company’s equity investment, without a readily determinable fair value, is the less-than-1% ownership interest in New Markets (BVI) Limited (Microconnect), which is accounted for in accordance with ASC 321-10-35-2, 35-3, and 35-4, instead of the “other than temporary” method mentioned in Note 2(n) of the consolidated financial statements of the Company for the years ended March 31, 2025 and 2024. Specifically, the Company performed a qualitative assessment for impairment indicators according to ASC 321-10-35-3 as of March 31, 2025 and 2024, respectively. The Company identified impairment indicators, including significant operating losses and… response letter →
HOULIHAN LOKEY, INC. (HLI) · 2026-01-30 · Form 10-K for the Fiscal Year Ended March 31, 2025 Form 8-K filed January 29, 2026 · Comment 1 · Non-GAAP Financial Measures, page 5 Agreed to revise
Staff comment: Please revise your disclosures in future filings to further discuss the reasons why you believe that presentation of these non-GAAP financial measures provide useful information to investors and describe each of the adjusting items. Refer to paragraph (e)(1)(i)(C) of Item 10 of Regulation S-K. letter →
Company response: The Company respectfully acknowledges the Staff’s comment. In future filings, the Company will revise its disclosures to further discuss the reasons why it believes that presentation of its non-GAAP financial measures provides useful information to investors and will describe each of the adjusting items in accordance with paragraph (e)(1)(i)(C) of Item 10 of Regulation S-K. The Company’s revised disclosure will read as follows: “Non-GAAP Financial Measures As a supplement to our financial measures presented in accordance with U.S. Generally Accepted Accounting Principles (“GAAP”), the Company presents certain adjusted (non-GAAP) measures of financial performance. These non-GAAP financial… response letter →
HOULIHAN LOKEY, INC. (HLI) · 2026-01-30 · Form 10-K for the Fiscal Year Ended March 31, 2025 Form 8-K filed January 29, 2026 · Comment 2 · Reconciliation of GAAP to Adjusted Financial Information, page 8 Responded
Staff comment: We note the adjustments for "acquisition related compensation and benefits" in each of your non-GAAP measures appear to include deferred retention payments related to certain acquisitions. Please tell us and quantify the components comprising each of this adjustment for each period presented and clarify whether these payments are settled in cash and require continued employment. As part of your response, please explain how you determined that these were not normal, recurring, cash operating expenses of your business. Refer to Question 100.01 of the non-GAAP C&DIs. letter →
Company response: , please explain how you determined that these were not normal, recurring, cash operating expenses of your business. Refer to Question 100.01 of the non-GAAP C&DIs. Response : The Company respectfully acknowledges the Staff’s comment and has considered the guidance set forth in Question 100.01 of the Compliance and Disclosure Interpretations related to non-GAAP measures (“ C&DI 100.01 ”). The Company believes that making adjustments to exclude acquisition related compensation and benefits is appropriate and consistent with the guidance provided in C&DI 100.01 and further believes that such adjustments enhance the clarity and usefulness of the Company’s non-GAAP financial measures for its… response letter →
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
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- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
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- RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
- SEC – Corporation Finance Interpretations (SEC · Regulator · Free)
- SEC – Financial Reporting Manual (SEC · Regulator · Free)
- The Monday Filer – SEC reporting Excel templates (The Monday Filer · Template vendor · Paid)
- UnfoldCFO – 10-K Disclosure Checklist (UnfoldCFO · Template vendor · See site)
- Workiva Marketplace – SEC Reporting Process Checklist (Workiva · Template vendor · Requires Workiva license)