Monday, December 21, 2009

The Codification and SEC requirements

What about the Codification and SEC requirements?

Public companies have separately authoritative requirements from the SEC (U.S. Securities and Exchange Commission) that pertain to environmental disclosure. Those requirements were not made part of FASB’s (Financial Accounting Standards Board) Codification instructions, per se.

Instead, relevant portions of authoritative content issued by the SEC and selected SEC staff interpretations and administrative guidance are shown in the Codification as a convenience to users, for reference purposes only, according to FASB. FASB attempts to make it clear that the Codification does not replace or affect requirements or guidance issued by the SEC or its staff for public companies in their filings with the SEC.

The Codification’s SEC content is held in separate Sections, with headings that begin with the letter S. For example, FASB ASC Subtopic 450-20 (for loss contingencies) has SEC content in:

  • S00 Status
  • S25 Recognition
  • S30 Initial Measurement
  • S50 Disclosure
  • S75 XBRL Elements
  • S99 SEC Materials

Meanwhile, there is no SEC content in FASB ASC Subtopic 410-20 (for asset retirement obligations) or in FASB ASC Subtopic 820-10 (for fair value measurement), as indicated by no Section headings beginning with the letter S.

FASB reminds users that SEC content being in the Codification does not affect the SEC’s normal update procedures for the information. Users may find delays between SEC changes and FASB’s incorporation of the modified text in the Codification.

The Codification does not contain all SEC guidance. It excludes content outside the scope of basic financial statements. Notably, and potentially pertaining to an entity’s environmental liabilities, it does not include SEC content from SEC Regulation S-K, Item 303, about Management’s Discussion and Analysis.