Is sufficient disclosure of past material changes in critical accounting estimates already required under current MD&A requirements?
Response: In our view, existing MD&A rules require discussion and analysis of material changes in all estimates (whether defined as critical or not) that impact financial results. Requiring a discussion of changes in critical accounting estimates in this new section of MD&A and disclosure of changes in other “non-critical”, but possibly material, accounting estimates in another section of MD&A would seem confusing. • Question: Is a three-year period the most appropriate period of time over which investors should consider changes? If not, why would a shorter or longer period be more appropriate? Response: Generally, we believe a three-year historic period for considering changes in critical accounting estimates is appropriate and consistent with other information that is generally discussed in MD&A. However, in a discussion of trend information, reference to the five-year data presented pursuant to Item 301 of Regulation S-K may be required, including reference to changes in critical es
