Does Item 10(e) of Regulation S-K prohibit the discussion in MD&A of segment information determined in conformity with FASB Statement 131?
Answer 19: No. A company may discuss segments or other subdivisions of its business in the MD&A, and may be required to do so if such a discussion is necessary to an understanding of the business. Such a discussion generally would include the measures reported in the footnotes to the company’s consolidated financial statements in accordance with FASB Statement 131. FASB Statement 131 requires footnote disclosure of segment profit or loss, segment total assets, and other specified segment measures. FASB Statement 131 also requires the footnote to include a reconciliation of those segment measures to consolidated amounts determined in accordance with GAAP. In a company’s disclosure document, if the first discussion of the segment profit or loss measure precedes the financial statements for example, in the MD&A the company should either: (1) present the FASB Statement 131-required information in the MD&A; or (2) include a cross reference in the MD&A to the FASB Statement 131-required info
