Specialty & Consumer Finance
5 SEC staff comments and 5 disclosure examples from companies in this industry.
SIC codes included: 6199 Finance Services, 6189 Asset-Backed Securities, 6153 Short-Term Business Credit Institutions, 6141 Personal Credit Institutions, 6163 Loan Brokers
Disclosure examples by topic
Specialty & Consumer Finance: Crypto assets (ASU 2023-08)4 examplesSpecialty & Consumer Finance: Non-GAAP measures in MD&A1 example
What the SEC staff asked companies in this industry
MD&A: Results & Known Trends (2)KPIs, Metrics & Earnings Calls (1)Crypto Assets (1)Liquidity & Capital Resources (1)Risk Factors (1)
Affirm Holdings, Inc. (AFRM) · 2026-03-06 · Form 10-K for the Fiscal Year Ended June 30, 2025 · Comment 1 · Overview, page 61 Agreed to revise
Staff comment: Please revise, in future filings, to provide a discussion of financial condition and changes in financial condition for the periods presented in accordance with Item 303(b) of Regulation S-K. As it relates to changes in your loan balance from period to period, include quantification and discussion of factors driving the change by loan product (e.g., Pay-in-X, 0% annual percentage rate (“APR”) monthly installment loans and interest-bearing monthly installment loans.). In this regard, we note that you quantify the percentage of GMV by loan product for each period on page 62. letter →
Company response: The Company respectfully acknowledges the Staff's comment. In future filings, beginning with the Quarterly Report on Form 10-Q for the fiscal quarter ending March 31, 2026, we will revise the discussion of financial condition under Item 303(b) of Regulation S-K to provide disclosure of material period-over-period changes in our loan balances by product type, including quantification and discussion of the factors driving material changes. Results of Operations Comparison of the Years Ended June 30, 2025 and 2024, page 68 response letter →
Affirm Holdings, Inc. (AFRM) · 2026-03-06 · Form 10-K for the Fiscal Year Ended June 30, 2025 · Comment 2 · Comparison of the Years Ended June 30, 2025 and 2024, page 68 Agreed to revise
Staff comment: In future filings, please expand your discussion of period-over-period changes by revenue line item to also disclose changes in the weighted average fee rates, interest rates and expected weighted average loan duration, to the extent applicable or appropriate, for the differing loan portfolio products for each of the periods presented. In this regard, we note that your current discussion indicates a 31% increase in your merchant network revenue from June 30, 2024 to June 30, 2025, while GMV grew by 38% over the same periods. Similarly, we note that card network revenue grew by 53% while GMV grew by 45% over the same periods. Refer to Item 303(b)(2) of Regulation S-K. letter →
Company response: The Company respectfully acknowledges the Staff's comment and advises the Staff that, beginning with the Quarterly Report on Form 10-Q for the fiscal quarter ending March 31, 2026, the Company will expand its MD&A discussion of period-over-period changes in revenue line items to decompose material changes into their rate and volume components, to the extent applicable and material. * * * * * * response letter →
SkyAI, Inc. (SKYA, SKYAW) · 2025-11-26 · Sharps Technology, Inc. Registration Statement on Form S-3 Filed September 15, 2025 · Comment 1 · General Agreed to revise
Staff comment: We note your disclosure that you have adopted a Treasury Policy under which the principal holding in your treasury reserve on the balance sheet will be allocated to digital assets, starting with SOL, as well as your disclosure that you do not intend to allocate treasury assets to other digital assets in the near term. We also note that the financial statements included in your Form 10-Q for the period ended September 30, 2025 include USDC and USDT holdings. Please revise your disclosure to: • Provide greater details regarding any plans to acquire and hold digital assets, including in what proportions and the anticipated timeline. In addition, please revise to provide a definition or more… letter →
Company response: The Company acknowledges the Staff’s comment and has revised the Registration Statement accordingly. Please see pages 1 through 5 of the Registration Statement for further details. response letter →
SkyAI, Inc. (SKYA, SKYAW) · 2025-11-26 · Sharps Technology, Inc. Registration Statement on Form S-3 Filed September 15, 2025 · Comment 2 · intend to generate profit through this strategy. Agreed to revise
Staff comment: Please revise to provide additional disclosure regarding SOL and your staking plans. For example purposes only: • Disclose your policies and procedures regarding your plans to stake Solana, including how much of your SOL you intend to stake. • Revise to provide greater detail explaining how agreements with staking providers will operate. • If material, add a risk factor addressing any liquidity risks related to your staking plans. • Identify the custodians that hold and will hold your digital assets and disclose the material terms of the custody arrangements, including the amount and limitations of any insurance coverage. letter →
Company response: The Company acknowledges the Staff’s comment and has revised the Registration Statement accordingly. Please see pages 2 through 7 of the Registration Statement for further details. response letter →
SkyAI, Inc. (SKYA, SKYAW) · 2025-11-26 · Sharps Technology, Inc. Registration Statement on Form S-3 Filed September 15, 2025 · Comment 3 · of any insurance coverage. Agreed to revise
Staff comment: We note that your Form 8-K furnished September 2, 2025 discloses that you entered into Consulting and Strategic Advisor Agreements on August 28, 2025. Please disclose how compensation for SOL Edge Ltd will be calculated. Please also disclose the material terms of the Investment Guidelines. letter →
Company response: The Company acknowledges the Staff’s comment and has revised the Registration Statement accordingly. Please see page 2 of the Registration Statement for further details. * * * We thank you for your review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact to our counsel, Jonathan Deblinger, Esq. at jdeblinger@egsllp.com or by telephone at (212) 370-1300. response letter →
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Grant Thornton Insights (Grant Thornton · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- 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)