The Language of Business | Jamie Dordik & Utkarsha on SEC Reporting

In this episode of Finrep's podcast, host Utkarsha Chourasia sits down with Jamie Dordik, a longtime SEC reporting and technical accounting leader, to look at SEC reporting from the reporting owner's seat. Jamie traces a path across 28 years in the field — from audit at Ernst & Young to the New York Stock Exchange, the FASB standard-setting side, and reporting roles at IBM, PepsiCo, and Booking Holdings, to leading SEC reporting and technical accounting at a fintech today — and explains how moving between technical and process roles, rather than staying in one lane, shapes the way she runs a quarter.

The conversation covers why SEC reporting is really project management rather than number-crunching, what a quarter looks like from close to filing, how the reporting team sits in the middle of legal, Treasury, and the business on things like risk factors, how a new disclosure standard goes from ASU to memo to filing, and how she handles genuinely gray judgment calls. Jamie also talks about reading a standard's basis for conclusions after her time at the FASB, and where AI belongs — and does not belong — in work that ultimately comes down to human judgment.

What you'll learn:

• Why SEC reporting is project management across the whole company, not just number-crunching

• What a quarter actually looks like from close to filing, and where the crunch really is

• How the reporting team brokers risk factors and disclosures between legal, Treasury, and the business

• How to take a new disclosure standard from ASU to memo to filing

• Where AI helps as an "assistant," and why gray judgment calls still need a human

Tune in to hear how the technical, process, and standard-setting sides of accounting actually fit together.

SEC Reporting Journal — Season 2

The Language of Business | Jamie Dordik & Utkarsha on SEC Reporting

Utkarsha:
Welcome, everyone, to the second season of SEC Reporting Journal, brought to you by Finrep AI — a purpose-built AI for financial research and reporting. Today I have with me Jamie Dordik. She has built a career at the intersection of financial integrity and organizational change, and has led reporting functions at some of the most recognized names in global business — from PepsiCo to IBM to Booking Holdings, just to name a few. She's now bringing that depth to our audience, and I'm really excited to have her. Jamie, I'd love for you to introduce yourself — talk about where you are right now, what controllership is, and how you ended up specializing in this space.

Jamie:
Thank you very much. I've been in the accounting space for over 28 years now — I can't believe it's gone so fast. I started in big four — at the time it was big six — at Ernst & Young, and did the typical audit route. After about three years I left to go to the New York Stock Exchange, spent a couple of years there, and then went to one of my clients, a publicly traded smaller SEC company, as their assistant controller. That, around 2005, is really what brought me into the SEC reporting world. And while I've left those specific roles for other opportunities — working at the FASB, and my role at Booking Holdings before coming to where I am now — I always seem to gravitate back to SEC reporting. It's my comfort zone, and I think I excel in it. People assume accounting means you're an Excel jockey crunching numbers all day, but in SEC reporting you're really project-managing financial statements for the public to absorb. You work with all different groups across the company — legal, compliance, FP&A, operational teams — so you really understand what's going on in the business, because generally anything big that happens has some accounting impact and needs to be disclosed in the SEC reports. I always felt it was a great place to be — a little more out of the weeds, understanding the big picture. That's why I keep coming back to these roles, and why I'm in the role I'm in now.

Utkarsha:
Someone starting out in SEC reporting usually finds it a daunting field — people don't approach it with the mindset that they'll get to know so much about the company. They think of it as grind work, so hard. But from what you're saying, yes, it has all of that, but it also shows you a much bigger side of the business than almost any other role.

Jamie:
Definitely. Going into it, I was very much like, "wow, what did I get myself into?" But it's a little predictable every quarter — you know when the quarter's ending and when your financial statements are due, so whether you're done or not, you sort of have to be done. For somebody Type-A like me, who wants to know which days I'll be really busy so I can plan ahead, it's a good role — versus other areas that are much more fire drills. Don't get me wrong, fire drills come up; you also oversee technical accounting, which can happen any time during the year and have accounting implications you have to assess. But for the most part I try to make the SEC function into a well-oiled, repeatable machine at every company I'm at.

Utkarsha:
It's interesting that you moved from audit at EY into these very different roles — the NYSE, the FASB. That's not the path people usually take. What made you do that, and what was it like?

Jamie:
Actually, I went from Ernst & Young to the New York Stock Exchange first. This was around the time of the Enron collapse, when Arthur Andersen went out of business and we were taking on a lot of their clients — it was a little bit crazy. I said, I don't really see myself becoming a partner at Ernst & Young; I want to make a move, and none of the roles I was being presented with excited me. Someone I'd worked closely with at EY had gone to the New York Stock Exchange in a role that was really not accounting — it was financial compliance, ensuring that publicly traded companies listed on the exchange were meeting our standards, like a certain market cap and share price. When they fell below — due to news, bankruptcy, or other transitions — they'd work with our team to come up with a business plan, which we'd bring to a committee quarterly to see how they were tracking against their goals. It was a small group, and while it wasn't an accounting role, we all had a big-four, big-six background. I thought it was a good change out of accounting — learn a bit about the markets, down on Wall Street, and I was young. It was a really great group; I learned a lot about the markets, and I met one of my closest work friends there, who isn't even in accounting. It was good to get out of the big four at that time.

Utkarsha:
Having watched the standards get made from inside the FASB — when a new issue comes out, do you read it differently than most preparers would? Do most people skip the basis for conclusions?

Jamie:
I worked at the FASB for about three years. I'd decided I wanted to hone in on my technical accounting skills, which really complement SEC reporting. In most companies, like where I am now, the SEC reporting role is combined with technical accounting — some companies separate them, but in many it's one role. So you're doing the SEC reporting but also understanding accounting standards: what implication they have for the company, what disclosures will be necessary, how the accounting has to be done. Being at the FASB taught me a lot more about how to understand the codification — how everything is presented when decisions are made. You write the standard update, but it goes through a lot of iterations through the board, and ultimately the standards are not prescriptive, and they're not meant to be — they're much more principles-based. But when things are principles-based, it's not always black and white how you apply them. So the basis for conclusions really gets into the mindset of the rule-makers as they made the decisions, and it definitely helps. When I'm looking at a new standard, I look at the basis for conclusions — whereas before working at the FASB, I probably would have just looked at what it's saying, tried to interpret it myself, and looked at the big-four guides. Also, every board meeting is recorded and available to anybody, so it's really informative to understand what went into the decision-making process — which, if I hadn't worked there, wouldn't even have been on my radar.

Utkarsha:
When you moved to Booking Holdings, you stepped from external reporting and technical accounting into a global process owner role for contract management. What was that like?

Jamie:
I did two roles there. I came in doing SEC reporting and technical accounting, but I was handling more of the technical accounting — I was in that role for two years. Then I moved to the global process owner role, which wasn't even in the accounting group.

Utkarsha:
I feel like you've shifted between technical and other roles back and forth a lot — it's been a pattern from the start of your career. I think you enjoyed the other side, then realized you love your technical accounting space too, so you moved back, and then thought, maybe I should look into this side as well. That shifting is what made you who you are today, because you hold both spaces — you understand everything from scratch. People usually stay in one lane, especially in SEC reporting; they're very constricted about changing fields. So when I hear you speak, I understand you don't just come from the technical accounting side, because you've had the courage to move around, and I really value and respect that. Thank you. As we're approaching the quarter, could you talk more about what a typical quarter looks like, from close to filing?

Jamie:
Sure. Yesterday was the last day of the quarter, so today is the first day of the close period. At my current organization I work very closely with the consolidation team, who gets all the numbers finalized, booked, and consolidated — we have many entities and different sets of books that need to be consolidated, with intercompany eliminations and all that fun stuff. That's done by another team, but we work hand in hand with them as things arise — as they're booking entries and saying, "we have this new contract, we've recorded the revenue this way, does this make sense?" Hopefully that comes up before the quarter as things are signed, but sometimes things fall through the cracks. Right now my team is waiting for the consolidations team and the controllers groups to finalize. We've built a calendar. I've been at larger companies where the books are closed within the fifth or sixth business day; I'm now at a smaller, almost-$1-billion-revenue company, where the close usually isn't completed in consolidation until around the fifteenth business day. So we've updated the 10-Q, rolled the numbers forward, and we have a very good skeleton with no financial information for this quarter yet — but the things we know happened during the quarter, we're building into our footnotes and MD&A. We're in this period of trying to have a really good starting draft, waiting for the financial information, and making sure any memos that support what happened during the quarter are done. We're working toward our disclosure committee meeting, which I own the presentation for. Today we had a meeting with the whole team to say, "okay, we need this information; is there anything we need to disclose to the disclosure committee; when can we have this by?" We need to get it to our chief accounting officer by a certain date so he can review it. So it's really about making sure the timeline is adhered to. Once the numbers are close and consolidated, my team populates the financial statements — the statement of cash flows, the P&L, the balance sheet, the equity roll-forward — and we work closely with the consolidations and controllers teams to make sure everything makes sense. If we see something that doesn't look right — a lot of times it's in the cash flow, which is still a very manual process — we work closely to understand the non-cash activity or how we've accounted for things. Then we get a draft one of the 10-Q, which we send to the whole finance organization and the CEO and CFO — it doesn't get detailed review at that level on draft one, because we know tax still needs to be worked on and there are still adjusting entries. Then it becomes a cycle of sending a new draft. We try to send about three drafts before finalizing for the audit committee, and within that there's a lot of churn and numbers changing — and when a number changes in the P&L, it ripples into the footnotes, into the MD&A, and balance-sheet changes flow into the cash flow. So for about a week and a half it's just ensuring everything's booked correctly, and that when changes are made, they flow to all the relevant sections of the filing. Then we file the first week in August. End to end it's a little over a month, but about two weeks is really crunch time. Our goal is always to roll forward the prior quarter before we even get to the quarter, so we have a clean base and do as much as we can ahead of time to avoid the scramble — but no matter how much you plan, things come up and change. Best-laid plans.

Utkarsha:
When you're working across so many teams, especially in that rigorous time, are there ever misconceptions or myths that people outside your team have about what your team does?

Jamie:
Yes. At my current company everybody's very willing to help — we're a very lean, small company, so everybody knows everybody. There are certain people you have to nudge — "we need you to review this revenue section, is this correct?" But throughout my career, there are people who are very busy with their day job, and this isn't their day job — it's something extra. So you have to be respectful of people's time. The way we try to get around it is by not coming across as asking for things late and expecting them done on a dime. We try to have clear expectations and send a clear timeline. This is very important in the 10-K process, which involves a lot of parties. It might seem elementary, but we'll have a call in November and say, "we want to do as much as we can in December — there's a whole business section drafted not by the accountants but by the business, with legal and other input — and we need you to look at it before the Christmas holiday, because when it comes back it may be hard to turn around." Some people listen, and some still wait until after the holiday. You have to be respectful and appreciative, but still push — because it's not their day job, and you keep in the back of your head that they're not working on this full-time.

Utkarsha:
From an outsider's perspective — or an SEC reporter's — what's something you constantly have to explain, a myth you debrief people on?

Jamie:
For example, updating the risk factors. Our legal team really owns the risk factors, but my team is the project manager for the whole document. So while we don't own — and aren't the subject-matter experts on — every piece, we own the end-to-end document, and we have to make sure things are running. Legal will say, "consult Treasury, can you look at this risk factor about Treasury?" and Treasury will say, "nothing's changed, leave it the same," and we'll say, "well, there's been a lot of activity in the markets, I think we need to update this." So there's a push and pull, and my team, being in the middle, has to ensure legal is getting what they need while Treasury isn't recreating the wheel. That's the balance.

Utkarsha:
When a new SEC disclosure requirement comes out — cybersecurity, ESG, or something else — what's the actual process of drafting it and getting it into the file?

Jamie:
As an ASU comes out, in every SEC reporting function I've been in, we have an ASU tracker that somebody on the team updates every quarter as new ASUs are issued. A newly issued standard generally doesn't go into effect for a year or more, but our job is to disclose in the document that there's a new standard. At that early point, we'd say we're evaluating the impact on our company — sometimes we'll say we don't expect it to be material, if we're certain, but we need to wait until we've assessed it. Then our team looks into it and understands what they're asking for. At the point where it starts getting implemented — companies with different year-ends might have adopted it in advance, and we're not early adopters — we use software that helps us with benchmarking, a research tool, to see what other companies are disclosing. We read the big-four interpretations, which always give a lot of good examples, and we put a memo together: this is the new standard, this is how it applies to us, this is how it changes the way we account for something, this is the new disclosure. That gets reviewed all the way up to our chief accountant, and then it goes to our auditors before we've even adopted the standard, to get approval — the disclosures, the new accounting treatment, all signed off. Generally the FASB gives you a year-plus for most updates to be put into play.

Utkarsha:
Most filing deadlines are fixed while the numbers keep moving. What's the closest you've come to a genuinely difficult quarter, and what got you through it?

Jamie:
When I was in my first SEC reporting role, very early in my career, there wasn't as much technology, so it always seemed like a fire drill — benchmarking was slower, there was no AI. But probably the closest call was at one of the companies I worked for, where something was brought up the day before we were due to file that could potentially have been an accounting error. We had to get our auditors on the phone, and our SOX and controls team, and hash out whether we'd have to make the change — and as I said, when you make a change it has a ripple effect, and there's always a chance a late change introduces something incorrect. Luckily we concluded it was not an error, and we were able to document it and sign off on the way the financials were. That was probably my closest experience — a day before filing, which might not sound like a lot, but you really want to be locked and loaded a couple of days before. Luckily I've never had anything that stressed me out that much.

Utkarsha:
You must be on edge during those times, because anything can pop up and you have to be hands-on.

Jamie:
Yes — and I'd rather file earlier. The more days you have, the more stress in some ways, because somebody's going to find something, or a subsequent event is going to pop up. I just want to file before something happens that I now have to add a whole new disclosure for.

Utkarsha:
How do you stay on top of SEC trends — through CPE, peer research? What areas are you watching most closely right now, and how do you make sure your disclosures are ahead of where attention is heading?

Jamie:
I like to listen to most of the big four — they have free quarterly webcasts that give you updates on trends. There's also another organization my company gets us a membership for, which twice a year holds SEC updates that my team and I attend virtually or in person. During the off quarters, between quarters, I do benchmarking — "we're disclosing this, but I think there's a better way; let's see how our peers do it." I'm currently in fintech, so let's see how other fintech companies are disclosing something we're hearing a lot about — should we be more careful, should we give more information? I also think it's important to always have the latest big-four guides on the big areas — revenue, leases — on hand for when things come up, so you have the latest and greatest interpretation.

Utkarsha:
Do SEC reporters have a community — a meetup or a space where you talk about what's new, like how AI is coming in? Earlier you said the work used to be very slow and done very differently. Is there a big SEC community out there that helps you progress, or is it very independent — you keeping tabs and being proactive yourself?

Jamie:
That's a really good question. There is — it's more for technical accounting, but I'm sure there's an SEC group on LinkedIn, and I want to get more involved, because if somebody has a question, everybody can probably benefit from the answer. I have a big network of people I've worked with who are still in SEC reporting, so I'll reach out — nothing confidential — and just ask, "what's your process for this? What's your best practice?" And I'll say, "let's meet up for a drink and catch up." I try to keep my network open with the people I've worked with, because they're all very smart, and a lot of them have stayed in the SEC reporting realm.

Utkarsha:
Sometimes the guidance is a little gray — whether it's on the MD&A, non-GAAP, or segment judgment. How do you decide how far to take a disclosure?

Jamie:
That's very important, and it's what makes me feel AI could never really take the place of an accountant — because it's your own experience, your understanding, your judgment. You need a human brain, because I can look at the same issue and give two different answers and almost fully support both. That's the challenge, and it keeps things interesting. There are many cut-and-dry questions where it's easy to know how to account for something. But a lot of revenue transactions, for example, have so many intricacies that not everybody has even seen certain ones. When we get to a point where we have an agreement and we're not sure — are we the principal or the agent, who's the customer — we use another big-four firm, outside our auditors, to bounce ideas off of. And we always try to have our own conclusion first, because we don't want to go in cold and just ask "what do you think?" So when something feels really gray, and it's not an area we've documented a conclusion on, we'll reach out to that person. I'll also always advise looking into the big-four guidance for excerpts that address the specific issue, or the basis for conclusions — the principal-agent question, for example, is something the FASB has had to make amendments to their standards on, because a lot of it is very gray and, without becoming too prescriptive, they want to give more guidance. So we do a lot of research and benchmarking. There's a lot you can see in financial statements about how things are accounted for — you can understand the overall policy, but that doesn't always give you the exact answer for how they're recording things. So it's a combination of all of that. A goal of mine is to build a really comprehensive technical accounting library at my current company, so anybody looking at accounting — even a small accountant looking to book a payroll journal entry with an interesting situation — can look at the guidance and then speak with us. Not everything is answered by looking at that or talking to our team, so it's really about knowing when to reach out and ask for help. What's great about my boss is that if we need to ask our third party, that's okay — because sometimes they even need to speak with their national office, and it's not always quick; something can take three months to decide, which seems crazy.

Utkarsha:
With so many judgment calls — not just yours, but even your seniors', who may have to reach out elsewhere — let's talk about AI, because it's impacted every field, even one as niche as yours, which has so much grind an individual has to put in. Do you think there's a future for AI here, or will it always be a balance — a limitation where it reaches a ceiling?

Jamie:
AI helped in that, before AI, if I was researching an issue, I'd look at all the big-four guides, search for the key term, do a Google search, and try to find an instance. Now you just ask Claude, "have you heard of this situation? How do most companies account for it?" The thing with Claude — while great — and ChatGPT, while great, is that I've found errors. I'll say, "I think that's not correct, I think there was an update to the guidance," and it'll say, "yes, you're correct." So in the beginning I was struggling with how to use AI ethically, and I think of it as: AI is an assistant, just like if I hired an assistant who's doing research that took me hours or days, in much less time. But you always have to review it, just like when somebody gives you an analysis. I always ask for the support — "point me to the support in the FASB guidance, where does it say that in the papers" — and make sure I understand it. Even experienced with AI, giving a different prompt to the same question gives different answers, so there's a long way to go. But there's automation that could be done — not so much the thinking and understanding the technical implications, but some of the more manual work. We use a tool for our financials that's supposed to automatically update the document, but what we don't do well is pulling the data from our trial balance, so that if a change is made it automatically flows into our financial systems. There have been a lot of limitations there, but over the next few years I think AI will enable that, so there's less rework and checking, and more time for meaningful things.

Utkarsha:
I'm asking this not from your present or previous work specifically, but have you heard in the SEC reporter space whether companies are building their own AI tools — for security clearance — or sourcing tools like Claude into their systems? Is there a trend of companies incorporating an AI system built only for SEC reporting, or is it better to still use generic AI tools?

Jamie:
I don't know if I'm answering this correctly, but currently we're outsourcing. We're using Claude — we just got the enterprise license, and before that we had Copilot; now we have both. We also have a tool that has AI capabilities built into it, which we used before I even joined — it's the tool we use for benchmarking and disclosures, and now there's AI built into it, which isn't great yet, but I think they're making strides. And there's another company that came to us, which our investor relations team uses, that has a really good AI feature more honed in on financial statement preparation — we have trial access, and I think it's a really great tool. So at this point we're not building in-house, at least for SEC reporting — possibly for consolidations, they're looking to build some in-house AI tools — but right now, specifically for my area, we're outsourcing.

Utkarsha:
From what I understand, generic AI does a lot of work but hallucinates a lot. We've come across tools that are very specialized in the niche of SEC reporting, so tools are getting built around that, and that might be the future. You're the user, so you'd know more, but that's the kind of space I think we're heading toward — I just wanted to bring that out. Moving forward, do you think titles like the CPA will have the same importance they had before? In terms of education, certifications, and titles — do they hold the value they used to? For someone coming up, trying to get their license, should they focus just on certifications, or is there a balance?

Jamie:
I'm biased, because I'm a CPA and I think it holds a lot of value. Getting the license is always looked upon highly. Now, for accounting, you have to go to school, get your master's, take the CPA exam — which is very difficult — and stay current to remain an active CPA. I think it will still be valuable, even if you don't do accounting. I just went back to an accounting event at my alma mater, and a professor said accounting is really the language of business — so I think it is. A lot of my friends with children in college, I tell them to minor in accounting even if they major in marketing or management, because those areas without a license are a little more concerning regarding what AI is taking over — there's something to be said for having a specialized license. I'm not in tax, but that's another area that's very complicated, and tax accountants generally also have their CPAs. So I'd like to think it's always going to be a career. It might change in the way it looks — the lower-level roles, I'm not sure how that's going to work, because everybody has to start somewhere, but a lot of that might be taken over by AI. In the state of the way the world is going, a lot of careers are going to have to look at how they start kids out of college to learn and begin. What I said to my daughter — she's in high school — is that AI is great, but if you don't have the basis behind it and don't really understand what you're looking at, how would you even instruct it? Exactly. So I might use it for work, but I've had so much experience — while you can use AI to double-check what you're doing, you should really try to learn it on your own first. And that applies in every aspect of careers and life.

Utkarsha:
A lot of people watching this are probably early in their careers, so that's great advice. To wrap up: you said we need to stay updated with the trends, and you gave me some resources earlier — but a final word on resources, newsletters, communities, how to stay on top of things?

Jamie:
LinkedIn is an amazing resource that only in the past few years have I used in a way where you can find groups of people who share the same work product as you. As we were saying with SEC reporting, there are organizations that hold meetings where people get together and discuss things — I think that's really important. And going to conferences — even for a specific tool you're using for your SEC filing, not necessarily an accounting conference — you meet a ton of other accountants doing the same job, and you get to talk to each other. I really think networking is one of the best ways to grow your knowledge and your career, because you never know — I got two of my jobs through connections, not just through submitting my resume. Connections really do play a major role. People will see the value in you and where you've been. So don't be afraid to be proactive, and don't be afraid to join organizations. I still have connections with people I worked with at EY, and at the FASB — it's just good to stay in touch with people.

Utkarsha:
Thank you.