Have we appropriately tailored the proposed definition of the term “off-balance sheet arrangement” and the proposed disclosure to filter out disclosure that is unimportant to investors?
If not, how should we change the proposed definition or disclosure requirements? We believe that the proposed definition is appropriate. The more focused definition included in the proposed rule, in contrast to the broader definition in the Act, is warranted to avoid an overload of information for investors and to focus on the specific areas where additional disclosure is needed. We would, however, suggest that the Commission clarify that obligations under pension plans or similar arrangements should be excluded from the definition of off-balance sheet arrangements, similar to the rationale followed by the FASB in FIN 45, Guarantor’s Accounting and Disclosure Requirements for Guarantees, Including Indirect Guarantees of Indebtedness of Others (FIN 45). FIN 45 indicates that those items not within the scope of FAS 5, Accounting for contingencies, are also not within the scope of FIN 45. We also concur with the proposed exclusion from the definition of off-balance sheet arrangements of c
Related Questions
- There are lots of security term and definition pairs. What definitions does the stakeholder need to filter out before distributing a definition set to the RE team?
- Does the proposed definition of "non-GAAP financial measure" capture non-GAAP information where enhanced disclosure is appropriate?
- What is the FDAs proposed definition of the term "gluten"?
