The FASB codified the AICPA subsequent event rules for periods ending after June 15, 2009. ASU 2010-09 was issued to change some of the guidance in the original codification and to clarify other portions. This ASU is effective immediately except for the sections related to conduit bond obligors, which are effective for reporting periods ending after June 15, 2010.
Date through which subsequent events were evaluated
For public companies, this ASU retracts the requirement to disclose the date through which subsequent events have been evaluated and whether that date is the date the financial statement were issued or were available to be issued.
The definition of a public entity was removed and replaced with the definition of an SEC filer. An SEC filer is an entity that is required to file or furnish its financial statements with the SEC or the entity is subject to Section 12(i) of the Securities Exchange Act of 1934. Entities whose financial statements are filed with the SEC by another entity are not considered SEC filers.
Conduit Bond Obligor
A conduit bond obligor is now required to evaluate subsequent events through the date the statements are issued the same as an SEC filer.
A non-SEC filer must disclose the date through which subsequent events have been evaluated and whether that date is the date the statements were issued or were available to be issued.
For revised financial statements, a non-SEC filer must disclose the date through which subsequent events were evaluated for the original statements and for the revised statements.
Revised Financial Statements
Revised financial statements have been defined as financial statements that have been revised due to the correction of an error or retrospective application of U.S. GAAP.
So, basically, the FASB is saying we don’t have to put the date of filing in our SEC filings anymore. Many in my company felt the date was implied and it was silly to have to put the date in the filings.
Was there any controversy at your company over disclosing the date?