Deloitte
Accounting Research Tool
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Chapter 13 — Disclosure

13.8 Transition From Nonpublic to Public Entity Status

13.8 Transition From Nonpublic to Public Entity Status

Question 4 of SAB Topic 14.B discusses the SEC staff’s views on the disclosure requirements for share-based payment awards during an entity’s transition from nonpublic to public entity status (e.g., when filing its initial registration statement with the SEC).

Footnotes

1
At the conference, the SEC staff noted that valuations that appear to be unusual may be attributable to the peer companies selected when a market approach is used. Specifically, the staff indicated that there are often inconsistencies between the peer companies used by registrants and those used by the underwriters, which result in differences in the valuations. Accordingly, the staff encouraged registrants to talk to the underwriters “early and often” to avoid such inconsistencies.