On November 9, 2016, the SEC’s Division of Corporation Finance (the “Division”) revised certain sections of its Financial Reporting Manual (FRM).1 The most notable changes (1) clarify when pro forma financial information required by Regulation S-X, Article 11,2 can be omitted from an initial public offering (IPO) for an emerging growth company (EGC); (2) clarify when an EGC may present two years of target financial statements in a proxy statement;3 and (3) add guidance on the implementation of the FASB’s standards on leases (ASU 2016-024), disclosures about short-duration contracts (ASU 2015-095), and the preparation pro forma information subsequent to adoption of the new revenue recognition standard (ASU 2014-096), as amended by ASU 2015-14.7
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