2.1.2 Subsequent Events and Durational Concepts

Issue

A number of companies have reported subsequent events for concepts that are durations. However, in a number of cases, the durations are for periods that have an end date that is later than the date the report is actually issued.  For example, companies report a subsequent event with a duration that spans the period of the subsequent quarter.

Recommendation

For durational concepts reported as subsequent events, the end date should not exceed the report submission date.  The start date, however, could be the start of the subsequent period or the date that the transaction occurred.  Note, however, that the period should be consistent with the guidance of the SEC’s Staff Interpretations and FAQs Related to Interactive Data Disclosure – Question E.19 & E19.1 on the SEC’s website.

When reporting a subsequent event for a durational concept, the period should reflect the known period of the event.

In a number of cases, due to the nature of the reporting cycle, it can be difficult to determine what the exact report date will be and it is not feasible to change the context relative to the report date.  In addition, the filer may report that a subsequent event happened in a particular month, but the company report date was within the month. In these cases, the filer and/or their agents should use reasonable judgment to limit the end date of the context to be as close to the report date as possible.