By: George M.Wilson & Carol A. Stacey

On August 25, 2017, the staff in CorpFin updated their Financial Reporting Manual. The updates include:

A new section at the very beginning of the FRM that describes communications with the Office of the Chief Accountant in CorpFin (CF-OCA). It also includes a concise summary of some of the roles and functions of CF-OCA.

Section 2065 and the related index sections have been updated to clarify that questions about applying the guidance on abbreviated financial statements to a predecessor entity should be directed to CF-OCA.

Sections 10220.1 and 10220.5 have been updated to clarify the guidance on the omission of financial information from draft and filed registration statements when such information “relates to a historical period that the issuer reasonably believes will not be required to be included…at the time of the contemplated offering.” Included in the update are cross references to C&DI’s 101.04 and 101.05.

An interesting aspect of the revisions is how they adjust the FRM for the changes CorpFin Chief Accountant Mark Kronforst has made to organize the CF-OCA staff based on technical SEC reporting areas.

As always, your thoughts and comments are welcome!