Just as calendar-year companies begin gearing up for year-end reporting, Deloitte & Touche has summarized the thinking of the staff of the Securities and Exchange Commission's Division of Corporation Finance – at least as evidenced by the comment letters staff members have issued in 2010.

Deloitte published a 169-page report on trends and specific concerns raised in thousands of letters the SEC staff provided to specific public companies after reviewing their financial statements. Under Sarbanes-Oxley, the SEC is required to review disclosures and financial statements for every registrant at least once every three years. The comments that follow are available publicly through the SEC's Edgar database.

In 2010, Deloitte says the SEC's comment letters focus largely on revenue recognition, consolidations, loss contingencies, business combinations, fair value measurements, financial instruments, impairments, income taxes, and materiality -- many of the same issues that have been the subject of new accoutning rules and audit scrutiny the past few years. The SEC also provided plenty of comments on issues of concern to specific industry segments. Comments issued on other disclosure areas primarily focused on management discussion and analysis, risk factors, proxy disclosures, including executive compensation, non-GAAP financial measures, and material contracts.

With respect to the revenue recognition, the staff continues to focus on multiple-element arrangements and software revenue recognition. The staff often asks companies whether they have disclosed accounting policies for each material revenue stream and whether they have addressed uncertainties that would affect revenue recognition, Deloitte says.

The staff is looking hard at variable interest entities because new accounting rules require companies to consider who has effective control over an entity in deciding who should consolidate it to their financial statements. The staff also is looking hard at loss contingencies, examining whether companies are providing adequate disclosure about potential exposures that might lead to losses.

As the economy has improved and companies have started pursuing mergers and acquisitions, the SEC staff is looking at business combination accounting, Deloitte says. The staff is particularly interested in the accounting around intangible assets, including goodwill, assuring they are appropriately identified and valued. Comments often focus on valuation techniques that are used in the performance of goodwill impairment test and on the completeness of disclosures around fair value measurements.

Deloitte reviewed the letters to identify the common themes, which enables companies to consider staff views on specific issues as the year-end financial reporting process gets under way. Deloitte says the process can help companies improve their own financial statements and disclosures.