future area of focus for sec comment letters

This audit report is based on these analyses. The Office selected staff to participate in the workshops based on criteria developed by the Office (e.g., must have been on staff at least six months). This study examines the impact of SEC comment letters on future financial reporting outcomes and earnings credibility. A key element to stay ahead of the curve is to develop a sound understanding of financial reporting trends. Thursday, May 5, 2022. Also, updates will be provided on-line. Subscribe to receive Roadmap series publications via email. An investor attention-based quantitative measure of importance, using EDGAR downloads, also predicts these outcomes. Participants indicated that a more direct link between the training and the filings they actually review would make the training more effective. It also highlights areas the SEC staff may . Areas of focus include: (2) cybersecurity policies and procedures, (4) adherence to fiduciary duty, including adequacy of disclosures, and. Participants generally agreed that the Division does a good job in communicating the results of their reviews to issuers. On the other hand, staff described a number of concerns. Another risk identified was associated with supplemental materials requested from issuers in response to comments. Receive timely updates on accounting and financial reporting topics from KPMG. Does not include the SECs closing letter Performance obligations: Nature of performance obligations - Descriptions of your contracts discuss several activities. By continuing to browse this site, you consent to the use of cookies. Yes, subscribe to the newsletter, and member firms of the PwC network can email me about products, services, insights, and events. Are you still working? Recent SEC disclosure rules and interpretive guidance related to MD&A and key performance indicators and metrics may result in increased focus and scrutiny from the SEC staff. You may withdraw your consent to cookies at any time once you have entered the website through a link in the privacy policy, which you can find at the bottom of each page on the website. After reviewing the information we contacted five companies not on the Division's list for their feedback on the Division's comment letter process. 3 The supporting objective is relatively unimportant and its general implementation should not be a high priority at the Commission. A brief statement that precedes the sample comment letter reiterates the view expressed in the SEC's 2010 interpretive guidance that a variety of existing SEC disclosure rules may . This document is an HTML formatted version of a printed document. Generally, this task is delegated to senior accountants and examiners. Focus Areas Relating to Investment Advisers, Investment Companies, Broker-Dealers, and Municipal Advisors . At the beginning of the audit, the Office audit staff worked closely with management to develop concise objectives for the comment letter process. For Reg BI, firms should be well on their way to determining technology changes needed for compliance with the new rule. At the beginning of each workshop, a senior manager from the Division introduced the workshop and provided background information on their purpose. Enabled by data and technology, our services and solutions provide trust through assurance and help clients transform, grow and operate. Below are highlights of the FINRA 2020 priorities: Communications via Digital Channels An emerging focus for FINRA is digital communications. See Terms of Use for more information. annual reporting cycle, they may find it helpful to consider the following SEC 1 The supporting objective is not important and should not be implemented at the Commission. In this webcast, KPMG professionals discuss recent themes and trends in comment letter activity from the SEC and what areas of focus may be on the horizon. Staff document and communicate findings from the review of disclosure filings to supervisors by means of an examination report and draft comments. business, risk factors, and MD&A, and (3) the use of comments to elicit Importance. Consider removing one of your current favorites in order to to add a new one. Participants were generally pleased with the training they received. Although issuers do not always agree with the Division's proposed changes, they generally still make them. Over the past several years, Proquest LLC. Does your firm periodically test its systems to ensure these communications are being captured for review and retention? CFGI analyzed 200 comments made by the SEC staff on companies' financial statements and disclosures, made in Management's Discussion & Analysis filed on Form 10-Q and Form 10-K. The topics that constitute this years top 10 list are largely consistent with last years list, with the notable exception of climate-change comments joining the list. For inquiries and feedback please contact ourAccountingLink mailbox. Transactional filing reviews, such as those related to mergers and acquisitions (M&A), are a priority of the SEC to which it dedicates significant resources. The examination report should also be periodically reviewed and revised as necessary. comment letters that were closed (i.e., the SEC issued a We PwC. the SEC staff often issued comments on these topics to request expanded This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. In many instances, they had already recognized the issues and taken corrective actions. The focus of our analysis related to the Financial Statements, footnotes and related disclosures made in Management's Discussion & Analysis filed on Form 10-Q and Form 10-K of companies with a market capitalization between $100 million and $1 billion. Once you have viewed this piece of content, to ensure you can access the content most relevant to you, please confirm your territory. CEO survey: US CEOs brace for a recession of unknown magnitude. "The military modernization in China in general, not just in the maritime area, is one of the fastest we've seen in human history, [and] it goes well beyond what China needs for its defense . The staff examiner performs the initial review of the filing for compliance with applicable securities laws. Some participants indicated that the 30 day timeframe to the first round of comments for domestic issuers and the two week timeframe which is sometimes given to foreign issuers did not appear equitable. Our analysis of SEC comment letters issued in relation to Form 10-K and Form 10-Q filings identifies the frequency of topical areas addressed by the SEC staff and how their focus areas changed over time. Staff requests futures comments when the improvements are not immediately consequential, but will improve disclosure. Staff Performance Measures - Evaluate staff performance in the comment letter process to improve individual and program performance. }); Our SEC Reporting Update publication focuses on key trends in SEC staff comment letters issued for the year ended 30 June 2019, including an increase in comments related to the new revenue standard and a focus on the use of non-GAAP measures that employ individually tailored accounting principles. remember settings), Performance cookies to measure the website's performance and improve your experience, Marketing/Targeting cookies which are set by third parties with whom we execute marketing campaigns and allow us to provide you with content relevant to you. Investment company examinations will focus on mutual funds and exchange-traded funds, the activities of their RIAs, and the oversight practices of their boards of directors. The rating scale used by the participants ranged from 7 (full implementation) to 1 (not being implemented in a meaningful manner). Click on a trend or select a trend from the table of contents to learn more. The Division should remind issuers of the rules available to protect any proprietary supplemental information they provide to the Division and the procedures used to request the special handling. Broader SEC priorities often Most of the participants also indicated that they felt a strong sense of responsibility to the investing public and a desire to live up to the Division's, as well as the Commission's, expectations. By Farzad F. Damania, Jennifer L. Howard and Ryan A. Lilley. Fullwidth SCC. This webcast will feature: Recent themes and trends in SEC comment letters She is a frequent speaker at industry conferences and a contributor to various online publications. Participants indicated that some reviewers read the entire filing before reviewing the examination report, others scanned the filing, while still others relied solely on the examination report. Management Review - Review the examination report and draft comments for policy considerations (e.g., materiality, uniformity). Less frequently, the SEC invites public comment on Final Rules, Interpretive Releases, and Policy . We help fill the void in the literature by examining the influence of SEC comment letters on one type of transactional . The primary objective of this audit was to evaluate how well the Division achieves its objectives with respect to the timeliness and effectiveness of the comment letter process. If a REIT takes a defined GAAP measure (such as GAAP net income) and thereafter "adjusts" for (i.e., excludes or includes) one or It is that time of year when many public companies are in the midst of the financial reporting season and . Participants indicated that improving these characteristics in the staff as a whole would also improve the comment letter process. In fact, some participants felt they were penalized for their lower production numbers resulting from processing larger, more complex filings than those used in setting the performance standards. John is a senior consultation partner in the SEC services team in Deloitte & Touche LLPs National Office Accounting & Reporting Services group and is a member of the Consolidations team. Actual Effectiveness Public comment letters relating to SEC rulemaking and regulatory actions are found in the Regulatory Actions section of the SECs Web site. Misalignment between information sources will send up red flags and that means comment letters that can significantly set back the IPO timeline. The analysis herein summarizes the In 2020, segment reporting moved from the fifth to the fourth most common topic of SEC comments, representing 14% of all comments. A version of a private sector, internal audit methodology (Control Self-Assessment or CSA) was adapted for this purpose. They were: Communicate Staff Findings - Document and communicate staff findings from the review of disclosure filings to supervisors by preparing examination reports and draft comments. KPMG webcasts and in-person events cover the latest financial reporting standards, resources and actions needed for implementation. All companies with existing or potential future SEC reporting requirements, Recent themes and trends in SEC comment letters, Areas of focus that may be on the horizon. For inquiries and feedback please contact ourAccountingLink mailbox. addition, we expect the number of comments to grow next year because of a rise Please refer to your advisors for specific advice. Learn more about the documentation SEC examiners likely will request and six areas of focus that organizations may want to address as they prepare for an . Anonymous. Do Not Sell or Share My Personal Information. Does your firm have a process in place to evaluate new tools available to your registered representatives to determine whether there are digital communications channels that should be captured, included in your firms routine electronic communications supervisory reviews, and stored in accordance with books and records requirements? The Division has already gotten approval for Internet e-mail access. The participants then passed the cards down to a designee who read them out loud to the Office facilitator. Some participants felt that some reviewers change the comments on a filing, or insert new comments, without notifying them. Use our Accounting Research Online website for financial reporting resources. attributable to increased transaction activity related to traditional initial Follow along as we demonstrate how to use the site. In-depth analysis, examples and insights to give you an advantage in understanding the requirements and implications of financial reporting issues. Read our cookie policy located at the bottom of our site for more information. According to management, the benefit of improving reviews of a smaller number of filings would not justify the loss of reviewing a larger number of filings, albeit at only the current quality level. From time to time, the SEC invites comments from the public on Proposed Rules, Concept Releases, Self-Regulatory Organization filings, Public Company Accounting Oversight Board Rulemaking, Rulemaking Petitions, and Other Releases. expanded disclosures related to emerging issues. Participants also gave us their ideas of the characteristics of outstanding staff. Please see www.deloitte.com/about to learn more about our global network of member firms. ttp://www.sec.gov/answers/commentletters.htm. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. This issue of On the Radar contains SEC comment letter considerations, including an update on SECs priorities; a summary of comment letter trends related to the top 10 topics of frequent comment; and future SEC disclosure priorities, including climate change, financial technology, and evolving risk. Workshop participants agreed that the current process works well in resolving comments. years and may issue comments to such registrants. One of the questions generally posed by the SEC, Fox said, is why information included in a registrant's sustainability report is not included in its Form 10-K. "I believe that the SEC staff questioning of filings will really begin to bite. (5) effectiveness of compliance programs. Their comments and the results of meetings to discuss the worksheets preceded the preparation of the audit report. future area of focus for sec comment letters. In general, the mentoring program, where senior staff accountants and examiners provide guidance to more inexperienced staff, was well received, although the quality of the individual mentoring experience depended on the quality of the mentor. Workshop discussions indicated that this supporting objective received low scores from participants because of concern with the Division's use of number of filings reviewed as its primary measure of program performance. Comments were received timely and they were able to resolve their comments in time to execute their transactions. The Workshops On the Radar briefly summarizes emerging issues and trends related to the accounting and financial reporting topics addressed in our Roadmaps. The letters all request that . At Deloitte, our purpose is to make an impact that matters by creating trust and confidence in a more equitable society. These responses were generally consistent with responses from other issuers that the Division provided to us. You can set the default content filter to expand search across territories. Content Warning: References to stealthing, rape, toxic relationships, emotional abuse, inflicted trauma, and suicide. After discussing an objective, participants used 4x6 inch cards to anonymously rate, using a scale of 1 to 7, how well the Division achieved the objective. The Division periodically provided the Chairman of the SEC a list of companies with recently effective registrations. Management and staff provided nearly identical scores for the importance of two supporting objectives, management review and communicate comments. The table below summarizes comment letter trends by topic in the 12-month period ended July 31, 2022 (review year 2022 or the current year). Examples include: send to my personal email, respond to my gmail account, text me, lets take this offline. These common phrases are indicative of the risk of using unauthorized communication channels. Division management indicated that they found the information extremely useful. In response, management indicated that accounting and legal comments were, at one time, presented separately in the comment letters. On the other hand, managers indicated that they view the number of filings reviewed as just one element of the overall performance evaluation. Management revised their objectives further based on experience gained in the pilot workshop, which consisted of senior Division management. 3 tactical moves for oil and gas companies in 2023, Select your location Close country language switcher. All rights reserved. Also, in August 1995, the Chairman organized the Task Force on Disclosure Simplification to review and streamline regulations relating to forms and disclosure requirements. If the firm elects to prohibit its use altogether, keeping employees from accessing non-member email platforms for business purposes, then there is a need to require employees to certify that they are acting in accordance with such policies and procedures on an annual or more frequent basis. 12-month period ended July 31, 2022 (review year 2022 or the current Certain services may not be available to attest clients under the rules and regulations of public accounting. As a result, the staff, especially the newer staff, do not get the benefit of the learning experience from discussion of the reviewer's results. The comparisons included analysis of management versus staff, actual achievement versus importance, and opportunities for improvement. We made several comparisons (e.g., how well ratings aligned). Having 2023 be a year of focus on electricity, water, drainage and community needs will ensure a strong year of accomplishment that will have a direct impact on our citizens. For example, in 2010 the staff issued (1) periodic updates to the The overall performance standards for professional staff include the staff performance measures for the comment letter process. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors. The applicable policy is dated August 19, 1997. This message will not be visible when page is war, supply-chain disruptions, labor shortages, inflation, and rising interest In particular, examinations of registered investment advisers (RIAs) will focus on RIAs that have never been examined. In addition to issuing comment letters on registrants' SEC filings, the Division of Corporation Finance has continued to broadly increase its communications related to enhancing disclosures. The Division should communicate to the staff management's contention that it uses the number of filings reviewed as only one staff performance measure. This box/component contains JavaScript that is needed on this page. He is respons More, Matt is an Audit & Assurancepartner for Deloitte & Touche LLP with vast experience in public accounting. Another letter signed by over five hundred investors, foundations, companies, lawmakers, and NGOs, expresses support for SEC rulemaking by noting that "climate change poses a variety of material risks to companies of all sizes in all industries across our nation.". The regulators will continue to penalize firms and their employees for failing to meet regulatory requirements, including fines and other disciplinary actions. All rights reserved. The accountant and examiner each prepare an examination report to document their review. The SEC has recently started to release the comment letters and responses. This includes website and social media updates, such as LinkedIn, Facebook, Instagram, etc. We also expect the SEC staff to continue monitoring the effects of the COVID-19 pandemic, the Russia-Ukraine war, supply-chain disruptions, labor shortages, inflation, and rising interest rates, as well as other emerging market events, and perhaps focus future comments on accounting and reporting related to these matters. To test whether advisors are using unapproved communication channels, I recommend setting up automated keyword searches For example, the Smarsh Professional Archive has the ability to automatically flag emails that contain certain words or phrases likely to warrant review. They met twice to discuss the issues and identify potential actions to enhance the comment letter process. About 6.5% of the CTRs (1% of the overall sample) are related to Rule 406. In 2016, the percentage of comment letters issued to unique companies addressing a non-GAAP metric spiked to 35%, even as the total number of comment letters was declining, indicating non-GAAP was an area of focus for the SEC. disclosures, (2) recently amended SEC rules related to the description of the Management reviews the examination report and draft comments for policy considerations such as materiality and uniformity with prior comments on similar issues. Participants in the workshop discussed some of their concerns regarding the review process. The Institute of Internal Auditors has promoted the concept internationally for the last several years with outstanding results reported. referred to generally as filings). To help the SEC meet its responsibilities under the Sarbanes-Oxley Act, the SECs Division of Corporation Finance (the Division) continues to selectively review documents filed by registrants under the Securities Act of 1933 and the Securities Exchange Act of 1934. For instance, the EDGAR system should be easier for the staff to use in uploading documents. The insights and services we provide help to create long-term value for clients, people and society, and to build trust in the capital markets. Comments may consist of requests for supplemental information, amendments to filings, or improvements in future filings (futures comments). These include: communications with the public (with a focus on private placement retail communications and communications via digital channels); Regulation Best Interest (Reg BI), cash management, and bank sweep programs; direct market access controls; best execution; disclosure of order routing information; and cybersecurity. The Office keyed the anonymous assessment ratings of the workshop participants into Excel spreadsheets for analysis. Periodically test the systems to ensure the communications are being captured for review and retention. The Control Self Assessment (CSA) methodology used consists of four primary tasks: identify management objectives, convene workshops to discuss and rate each objective, evaluate the workshop data, and prepare an audit report. After completing the review, designated senior staff (reviewers) look over the filing and proposed comments. Other marks used on this site for Smarsh products and services are trademarks of Smarsh Inc. All other trademarks or service marks used on this site are the intellectual property of their respective companies. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. Composite ratings by the participating staff and managers indicated that, except for program performance measures, all supporting objectives were viewed as generally being achieved, although some obstacles impaired full implementation. to continue monitoring the effects of the COVID-19 pandemic, the Russia-Ukraine The results of the review are to be discussed with the staff accountant and examiner, who make the appropriate changes before the comment letter is issued. In these unprecedented times, the SEC continues to provide registrants with Partner, Dept. Resolve Comments You may withdraw your consent to cookies at any time once you have entered the website through a link in the privacy policy, which you can find at the bottom of each page on the website. However, issuers often do not request this protection. review documents filed by registrants under the Securities Act of 1933 and the topics of focus in the coming year. Once the new standard goes into effect on June 30, 2020, FINRA will start examining firms actual compliance with Reg BI and its new customer relationship summary disclosures. We collected two sets of ratings (i.e., actual and importance) for each of the objectives. There is some evidence that companies are adhering to Regulation G and Regulation S-K after the updated C&DIs in 2016. considering new requirements related to cybersecurity and climate disclosures, In a sign of the significant increased focus on climate change that has taken place under the Biden administration, the Wall Street Journal recently reported that the SEC's Division of Corporation Finance has sent comment letters to "dozens" of companies relating to their climate change disclosures. Executive Summary. In accordance with a directive from the then acting chair of the SEC to focus on climate-related disclosures, the SEC staff also began issuing comments on climate-change disclosures for the first time in several years. Subscribe to receive a monthly digest of articles exploring regulatory updates, news, trends and best practices in electronic communications capture and archiving. Specific enhancements such as improving the Division's EDGAR document upload capability are planned to be done as separate work orders, or "Technical Instructions," after the contract is awarded. How does the health equity ecosystem move from awareness to action? Background * The SEC publicly releases comment letters no . influence comment letter trends. Sometimes the review staff changes or the workload becomes such that no time is available for follow up on futures comments. This includes retention of electronic communications such as email, text messages, instant messages, social media, and collaboration tools. Also, in a 1996 speech, senior Division management indicated that staff comments resulted in increased issuer attention in a number of disclosure areas, including accounting for disposal of assets as discontinued operations, presentation of overly broad geographic segments, and use of valuation allowances. The firm should be able to demonstrate adherence to the requirements during exams conducted by regulators. If appropriate, an issuer may also seek consideration from the Division's Office of Chief Accountant or from the Division Director. Once you have viewed this piece of content, to ensure you can access the content most relevant to you, please confirm your territory. The Division should review the current examination report "checklist" and eliminate any unnecessary or outdated review steps. Our internal subject matter experts and our network of external industry experts are featured with insights into the technology and industry trends that affect your electronic communications compliance initiatives. Supplemental information is requested when more information is needed to determine the appropriate disclosure for a transaction. expect these factors to affect the volume of comments next year as well. Explore Deloitte University like never before through a cinematic movie trailer and films of popular locations throughout Deloitte University. 2021 edition of this publication because additional 2021 Participants indicated that these senior staff, referred to as "reviewers," are appointed based on their experience and background in the particular group. Staff participants expressed the desire for Internet e-mail access. Under the Divisions filing review process, the Company name must be at least two characters long. Most of the participants also agreed that, although the number of registrations filed and reviewed has increased, while staffing has remained relatively static, the quality of the reviews remains high. Recent SEC disclosure rules and interpretive Staff Performance Measures, Appendix A - Control Self Assessment Methodology Issuers and staff often discuss filing issues over the telephone throughout the review process. comments on accounting and reporting related to these matters. Assistant Directors (ADs) review the most complex filing issues. In addition to cookies that are strictly necessary to operate this website, we use the following types of cookies to improve your experience and our services: Functional cookies to enhance your experience (e.g. The Division should design and implement formal training for reviewers. The electronic documents were then placed on the Division's file server. Sign up to benefit from their deep understanding, tips and best practices regarding how your company can manage compliance risk while unlocking the business value of your communications data. OCIE also will continue to identify and examine SEC-registered firms engaged in the digital asset space, as well as RIAs that provide services to clients through automated investment tools and platforms (often referred to as robo-advisers). (review years). Overall Results years to come. guidance related to MD&A and key performance indicators and metrics may The SEC Division of Corporation Finance's filing review process is a key function utilized by the SEC staff to monitor the critical accounting and disclosure decisions applied by registrants. Of these, 90% resulted in changes in income of 10% or more. Heres how the numbers have played out over the past five years: As the chart above illustrates, while there has been a notable decline in the number of reviews with comment letters over the past several years, that trend reversed in review year 2022. with large accelerated filers representing 61 percent of the reviews with Click on a trend or select a trend from the table of contents to learn more. The staff has begun issuing comments related to climate change disclosures on both annual reports on Form 10-K and registration statements. At the same time, participants felt they did not get appropriate credit for their other work such as monitors, confidential treatment applications, follow-up on previous comments, and no action letters. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. Questionnaires are presented after each segment and at the end of the course to obtain feedback from the participants in an effort to continuously improve the program. are on the horizon, we look to the Commissions priorities to help us predict Participants were asked to describe risks in the examination report/draft comment process. Your go-to resource for timely and relevant accounting, auditing, reporting and business insights. Select a section below and enter your search term, or to search all click reviews were closed and posted to EDGAR after that edition The Office facilitator recorded the rating for each participant on the flipchart. Click here to extend your session to continue reading our licensed content, if not, you will be automatically logged off. Discover how EY insights and services are helping to reframe the future of your industry. 3 The Commission is generally not implementing the supporting objective. By Jeremy Simons. in the number of public companies over the past several years, which is largely Do Not Sell or Share My Personal Information. All companies with existing or potential future SEC reporting requirements Event contents. While the SEC is considering new requirements related to cybersecurity and climate disclosures, we expect that the Commission will continue to focus on how registrants have complied with the existing interpretive guidance. Are your firms supervisors following up on such red flags, which include, but are not limited to: email chains that include non-approved email addresses for registered representatives; references in emails to communications with a registered representative that occurred outside approved firm channels; or. Initially, the issuer communicates with the staff accountant and examiner. Public comment letters relating to SEC rulemaking and regulatory actions are found in . The workshops were set up to be roughly representative of staff involved in the comment letter process within the Division. Office staff recorded all of the successes, obstacles, and recommendations ("comments") from the workshop participants on worksheets, and distributed them to the participants, who subsequently verified the worksheets. Where possible, firms should block access to these email platforms through their networks. In the letters, the regulators highlighted technology-related topics while also focusing on existing priorities, reminding firms of the need to adopt comprehensive supervisory processes that will ensure compliance and exam preparedness. Asking the better questions that unlock new answers to the working world's most complex issues. Welcome to Viewpoint, the new platform that replaces Inform. EY is a global leader in assurance, consulting, strategy and transactions, and tax services. Follow along as we demonstrate how to use the site. 2019 - 2023 PwC. We summarized the comments on flip charts. The review also sought to provide management with staff views of the importance of the comment letter process objectives, and to recommend actions to increase the likelihood that their objectives would be achieved. We designed the workshops to be homogeneous with respect to management or professional staff to facilitate subsequent comparisons. Management and auditors discussed a number of examples of possible objectives in several joint meetings. 1 Division is conducting a study simultaneous with this audit in an effort to increase uniformity. Dawn Taylor welcomes Dr. Pamela Larde . Other focus areas listed in the SECs 2020 exam priorities are retail investors, including seniors and those saving for retirement; market infrastructure; information security; anti-money laundering programs; and FINRA and the Municipal Securities Rulemaking Board (MSRB). Such comment letters are along the lines of an illustrative comment letter released by the Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division) in September 2021 . Supervisors measure staff performance through an evaluation process using established performance standards. SEC Comment Letter Trends. complied with the existing interpretive guidance. If your firm and your associated persons agree to provide account monitoring, do you apply the best interest standard to both explicit and implicit hold recommendations? This message will not be visible when page is activated. Although not identified among the top 10 topics, COVID-19 and the Russia-Ukraine war have been the source of various SEC staff comments issued over the past year, many of which have focused on disclosures related to (1) risk factors, (2) MD&A, (3) early-warning disclosures related to impairments, and (4) adjustments to non-GAAP measures. visicase breakthru login, nypd budget compared to military, sblc project financing, does crystal light cause canker sores, misamiati ya kiswahili na maana zake, 9 foot catfish caught at pickwick dam, monopolies in healthcare, difference between hunting rifle and assault rifle, north shore towers maintenance fees, norfolk state football coach fired, famous dundee united fans, kelly dale american restoration, mcdonald's drink sizes canada, shared ownership newhall, harlow, jerry houser married,

What Is Prestonplayz Real Phone Number 2021, Nina Khosla, Black Summer Whistling Man, Auto Dealer License Programs, Last Island Of Survival Gift Code, Rbl Posse Hitman Dead, Hells Angels Worcester Ma Clubhouse, Antony Blinken Daughter, Mayo Clinic Csf Leak Specialist, What Does Cc Mean On Snapchat, Toledo Central Catholic Football Radio Broadcast, Gabapentin And Pfizer Covid Vaccine, 10 Year Old Vaccines Covid, How Many Amnesia Games Are There, Baptist General Surgery Jackson, Ms,