CAQ Issues SEC Regulations Committee Highlights

SEC staff discusses current financial reporting matters at the September 2012 meeting

Summary

The Center for Audit Quality (CAQ) recently issued highlights of the joint meeting on September 25 between its SEC Regulations Committee (the Committee) and the SEC staff. This bulletin summarizes a variety of topics addressed at that meeting, including disclosures related to fair value measurements and the Iran Threat Reduction and Syria Human Rights Act, draft registration statements confidentially submitted for review by emerging growth companies, and comments related to certain practice issues with the contractual obligations table presentation. This bulletin also includes interpretation and implementation issues related to certain recent SEC releases.

The Committee meets periodically with the SEC staff to discuss emerging financial reporting issues relating to SEC rules and regulations. The highlights of joint meetings between the Committee and the SEC staff only summarize matters discussed and do not represent official positions of the AICPA or the CAQ, nor are they authoritative positions or interpretations issued by the SEC or its staff. The CAQ does not update or delete meeting highlights for subsequent positions taken by the SEC staff or for the issuance of subsequent highlights or authoritative accounting or auditing literature that supersedes the matters previously discussed.

1. Current financial reporting matters

   Fair value disclosures

   The SEC staff shared observations related to fair value disclosures resulting from their reviews of recent filings. These observations were categorized into three general areas related to the application of Accounting Standards Update (ASU) 2011-04, Amendments to Achieve Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs.

   Iran Threat Reduction and Syria Human Rights Act

   The SEC staff discussed the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), which was signed into law on August 10, 2012. The law was self-executing, meaning that no additional rulemaking is required for the disclosure requirements to be effective. The Act expands the types of transactions and other activities with Iran and Syria that are subject to sanctions and holds U.S. entities liable if their foreign subsidiaries undertake these transactions and activities.

   The Act adds new Section 13(r) to the Securities Exchange Act of 1934 (Exchange Act), requiring reporting companies to provide...