Preparing for an A+ grade: SEC comments on financials

By this point everyone knows that the financial statements you must provide to the SEC in Tier 2 Regulation A offerings must be audited by a CPA. We are seeing reputable CPAs offer their services at very reasonable prices for early-stage companies.

But companies need to know exactly what is covered in their agreement with the CPAs.

Does your contract with the CPA include responding to SEC comments on financial statements? The SEC review process involves both lawyers and accountants commenting on your filings, and you have to respond to those comments to the SEC’s satisfaction. You may also have to restate your financial statements, ie change them and get a new audit opinion. This happens more often than you probably realize! Make sure you know whether the accountant will be helping you with SEC inquiries, and whether the accountant’s fee includes restatements, or what they would charge in the event you have to restate your financial statements.

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