Reduce Quarter and Year-End Inefficiencies in Goodwill Impairment Assessment

A structured quarterly record of reporting-unit performance — calibrated to the transactions that created goodwill and ready for auditor and SEC review.

01
Audit Paradigm
PCAOB Spotlight — February 2025

The auditor's responsibilities with respect to data and significant assumptions generally are:

  • Test the accuracy and completeness of company-produced data.
  • Evaluate whether the significant assumptions are reasonable.
  • Evaluate assumptions based on the company's intent and ability to carry out a particular course of action.
Nick Says Solutions

Built for goodwill fair value support.

  • Efficient quarterly tracking of each reporting unit ("RU") performance.
  • Ongoing calibration to the original transaction(s) that created goodwill.
  • Shepherding the data gathering process in preparation for audit review and disclosure narratives in SEC filings.
  • Reduce the back-and-forth between the company and the audit team reviewing fair value estimates.
02
Level 3 Evidence
“Evaluate the reasonableness of observable and unobservable inputs used — and whether the inputs represent the assumptions that market participants would use.”
— PCAOB Staff Guidance · August 22, 2019

Nick Says captures the contemporaneous evidence behind each Level 3 input — the current market conditions, the calibration to the original transaction, and the methodology record that withstands auditor scrutiny.

03
Capability Groups

Structured workflow, from inputs to audit evidence.

Level 3 Inputs

Cash flow forecasts, margins, and growth rates. Estimates, KPIs, and milestones.

SAS No. 101 Fair Value Review

Longest and most intensive for Level 3 inputs — we help you prepare the evidence auditors need.

Quarterly Monitoring & Calibration

Efficient record-keeping of Level 3 inputs and ongoing calibration quarter after quarter.

Current Market Conditions

Better track and document contemporaneous evidence of current market conditions and the impact on internal forecasts (unobservable inputs).

Why this matters

Goodwill testing remains a top area of focus in SEC comment letters — and the evidence trail is the first things reviewers request.

04
SEC Comment Letter Trends

Goodwill testing remains a top area of focus in SEC comment letters.

Ernst & Young — Top 10 Comment Letter Topics
Year over year change in comment letter topics
Current period: 10/1/2024 – 9/30/2025
RankTopicRelative change vs prior periodAbsolute change vs prior period
1Non-GAAP measures
2Management's discussion and analysis
3Segment reporting
4Revenue recognition
5Goodwill and other intangibles
6Business combinations
7Inventory and cost of sales
8Debt, quasi-debt, warrants and equity
9Fair value measurement
10Disclosure controls and ICFR
Deloitte — Top 10 Topics in Reviews
Percentage of all reviews
12-month period ended July 31, 2025
MD&A
50%#1
Non-GAAP measures
37%#2
Segment reporting
23%#3
Revenue recognition
16%#4
Inventory and cost of sales
10%#5
Intangible assets and goodwill
10%#6
Signatures, exhibits, and agreements
9%#79
Acquisitions, mergers, and business combinations
8%#81
Debt
8%#92
Earnings per share (EPS)
7%#105
PwC — SEC Comment Letter Ranking
2025 ranking
12 months ended 30 June 2025
  1. 1Management's discussion and analysis
  2. 2Non-GAAP financial measures
  3. 3Segment reporting
  4. 4Revenue recognition
  5. 5Goodwill and intangible assets

Rankings reflect SEC comment letters issued to registrants with market capitalization of $75M or more on Forms 10-K and 10-Q from 1 July 2024 through 30 June 2025, excluding SPACs and other blank-check entities.

Sources: “SEC Reporting Update,” 2025, Ernst & Young, September 11, 2025; “SEC Comment Letter Considerations, Including Industry Insights,” Deloitte, November 2025; “SEC Comment Letter Trends,” PwC, November 6, 2025.

Start Your Goodwill Assessment

Bring structure, continuity, and a methodology record to your quarterly fair value practice.