Interview With Sunil Pandey: 14 Years in SEC Reporting — From Quarterly Filings to IPO Preparations

Hi Sunil, first of all, welcome to Finrep’s podcast and thank you for agreeing to a feature interview in our newsletter SEC Reporting Journal.

Thank you for having me!

To start with, could you tell us about your journey into SEC reporting? How did you end up in this specialized field?

After completing my MBA in finance, I dove straight into SEC reporting and have been working in this domain for the past 14 years. I've also worked extensively with Federal Reserve Bank regulatory reporting, as the U.S. has several regulators with equally important and mandatory requirements.

Throughout my career, I've worked with different multinational companies listed in the USA. What drew me to this field was the complexity and critical nature of the work – particularly challenging filings like S-1 registration documents for companies going public, which require five years of historical data, stringent auditing, and legal partnerships.

Can you walk us through what an end-to-end quarterly filing process looks like?

SEC reporting includes much more non-financial information compared to other regulatory reports. We coordinate with multiple teams – financial planning and analysis, accounting, HR, and legal teams for commitments and litigation matters.

The process starts with a roll-forward from the previous period. Once our reporting cycle closes (typically June 30th for Q2), we begin collecting data from across the entire company. This includes financial statement preparation, various schedules, and footnotes covering investments, fair value measurements, and derivatives.

We coordinate with different teams who provide data through email or upload to our portals and dashboards. The document goes through several review phases: first to the Disclosure Committee, then to the Management Committee, and finally to auditors for their review and consent (mandatory for 10-K, optional for 10-Q).

We have a 45-day timeline after quarter close, but we always aim to file earlier to avoid last-minute issues that could result in heavy penalties or even prevent us from going to market.

What was your most challenging experience with a late filing or unusual circumstance?

I once faced a critical situation on the last day of filing when our outsourced XBRL provider informed us they couldn't deliver the interactive data component. We immediately contacted our legal team and management committee, who advised us to file the 10-Q without XBRL first.

Our CEO and management committee emailed SEC personnel directly, explaining our situation and requesting an extension. We received a six to eight-hour extension for the XBRL filing, allowing us to complete both components and avoid penalties. This experience taught me the importance of having strong relationships with legal and management teams and maintaining open communication with regulators when facing genuine technical difficulties.

How do you handle new disclosure requirements, such as those emerging for AI, ESG, or cybersecurity?

When new disclosure requirements arise, we first review SEC guidelines and draft the required content, including any new tables or data requirements. The process involves three key steps: our SEC reporting team creates the initial draft, then it goes to the disclosure committee for review, and finally to our accounting policy team who ensures compliance with relevant accounting standards.

It's worth noting that ESG disclosure requirements have been put on hold pending further notice from recent SEC meetings, but we stay prepared for when new requirements do take effect.

What tools have you used throughout your career, and how has technology evolved?

I've used various SEC reporting tools throughout my career, including Edgar Online, Crossfire, and EG XBRL. Currently, I primarily work with Workiva's Wdesk, which has become quite popular in the SEC reporting industry.

The major advancement is automation and AI integration. We can now link Excel sheets directly to our ledger systems, with automatic daily refreshes at set times. This data flows automatically into our main documents, providing more time for analysis rather than manual data entry. We also provide different teams with read/write access, allowing risk teams, HR, and legal teams to input their data directly.

Are you experimenting with AI-based products in SEC reporting?

Everyone in SEC reporting is exploring AI tools, particularly for peer comparisons. When new requirements apply to large accelerated filers first, smaller companies can analyze how similar entities managed those changes. AI tools that can compare different filings and extract relevant data are incredibly valuable.

These tools also help with compliance by providing disclosure checklists aligned with accounting standards, ensuring we meet both audit requirements and regulatory compliance.

How do you stay current with industry trends and regulatory changes?

I regularly follow the SEC website's newsroom section, which provides day-by-day updates on regulatory changes, penalties, and new requirements. For example, I recently saw that a company was penalized $140 million – these real-world examples help understand enforcement trends.

The SEC website's press releases and newsroom are invaluable resources for staying informed about everything from ESG changes to cybersecurity requirements.

What trends are you seeing in SEC comment letters?

Comment letter focus varies by industry. For bank holding companies, SEC staff typically scrutinize asset and liability ratios, leverage ratios, and capital equity ratios. They compare our data with peer companies, focusing on accuracy and materiality.

While our filings are audited and subject to SOX compliance (sections 302 and 404), reducing misrepresentation risks, the SEC maintains stringent review processes. They also pay close attention to commitments and contingencies sections, particularly for any potential misrepresentation by legal teams.

How do you approach disclosures when guidance feels unclear?

When guidance is ambiguous, we research peer company filings to see how similar entities handle the disclosure. We also reference Financial Accounting Standards (FAS) for specific requirements and use SEC templates for non-financial information like executive compensation and risk factors.

This process involves our disclosure committee and accounting policy team, requiring significant effort in comparing guidelines, FAS standards, and peer disclosures. We typically have about 1.5 months between quarters to prepare, allowing time for thorough research and multiple committee meetings when needed.

What advice would you give someone new to SEC reporting?

First, read the entire document – not just your assigned section. Take time to understand how different parts interconnect. When you update investment data or reinsurance numbers in the balance sheet, it impacts investment footnotes and MD&A sections as well.

Understanding these connections helps avoid rounding errors and validation issues. If you know that updating one section affects others, you can proactively check those areas and maintain consistency across the document.

Also, familiarize yourself with the SEC website for upcoming changes and press releases. This gives you a broader perspective on the regulatory environment.

What improvements would you like to see in SEC reporting processes?

Internal collaboration is our biggest challenge. I'd love to see dashboard notifications within our tools that automatically alert data providers about upcoming deadlines. For example, if we need investment data by a specific date, the system could send notifications a few days prior.

Enhanced peer comparison capabilities within tools would also be valuable, along with automatic notifications about FAS changes and implementation timelines. Some tools are already incorporating SOX compliance forms directly into the platform, allowing reviewers to mark comments and track compliance measures.

What's your elevator pitch for someone considering SEC reporting as a career?

SEC reporting gives you the complete picture of a company – not just financial schedules, but everything from executive compensation to risk factors and liquidity ratios. You see both financial and non-financial aspects of how a company operates.

Once you work in SEC reporting, you understand how all pieces fit together. Even if you move to other areas later, you'll have valuable insights into data requirements, reporting guidelines, and how different sections interconnect. This comprehensive exposure makes SEC reporting an excellent foundation for any finance career.

Any funny or unusual disclosures you've encountered?

The most complex disclosures depend on your industry. In banking, it's typically fair value measurements and derivatives – these require significant effort and constantly changing assumptions, especially for Level 3 assets and liabilities.

Insurance companies deal with complex insurance liability, deferred acquisition costs, and reinsurance disclosures. Software companies face challenges with revenue recognition under ASC 606. Each industry has its particular pain points, but they all require deep dives into account-level details and sometimes even general journal entries to understand the underlying transactions.

Thank you Sunil for your time and your sharp insights into a world we know little about.

It’s a pleasure. Thank you.

Sunil's experience demonstrates the complexity and critical importance of SEC reporting in maintaining transparent capital markets. His insights into process improvements and technology adoption provide valuable guidance for both newcomers and veterans in the field.

Resources Recommended by Sunil:

• SEC website newsroom and press releases

• Industry-specific 10-K and 10-Q filings for peer comparison

• SEC training videos available on the agency website

• Workiva University and other tool-specific training programs

• Professional development through disclosure and management committee participation

P.S. If you wish to ask specific questions with CPAs and SEC Reporting Professionals in our forthcoming podcasts, feel free to comment them below.