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ASC 855 cutoff: available to be issued vs issued, private vs public

Private entities evaluate subsequent events through the date the financial statements are available to be issued; SEC filers use the date issued. Below: a timeline to set the cutoff, common traps, and 9 free practice questions.

The ruleNon-SEC entities evaluate subsequent events through the date the financial statements are available to be issued; SEC filers evaluate through the date issued. Events after that date are not subsequent events for those financial statements. Non-SEC entities disclose the evaluation date in the notes.

Try one first

Marlow Co., a private company, has a December 31, 20X5 year-end. Management authorized the 20X5 financial statements to be available to be issued on February 25, 20X6 (the private-company cutoff date for evaluating subsequent events). The statements were later provided to the company's bank on March 10, 20X6. Assume each event below is material if disclosure is otherwise required. Events: 1. On January 18, 20X6, a major customer who owed Marlow $900,000 at December 31, 20X5 filed for bankruptcy. The bankruptcy resulted from severe financial deterioration that existed before year-end and confirms the receivable was impaired at December 31. 2. On February 5, 20X6, a flood destroyed a warehouse that contained inventory shown on Marlow's December 31 balance sheet. 3. On March 3, 20X6, an uninsured fire destroyed a different production facility. Under ASC 855, which treatment is most appropriate for Marlow's December 31, 20X5 financial statements?
Hint

First identify the private-company evaluation cutoff date (when management authorized the statements to be available to be issued), then decide for each event whether it confirms a condition that existed at December 31 (adjust) or arose afterward (disclose or ignore if after the cutoff).

The timeline

  1. Day 0 (balance sheet date)Year-end financial position is measured

    Later events are assessed to determine if they relate to conditions existing at Day 0 (recognized) or arise after Day 0 (nonrecognized).

  2. After year-end, before cutoffEvidence about existing conditions emerges (for example, customer bankruptcy or litigation settlement)

    If it confirms conditions that existed at Day 0, adjust the year-end amounts.

  3. After year-end, before cutoffNew-condition event occurs (for example, a casualty unrelated to year-end conditions)

    Do not adjust. Disclose in the notes if material and within the evaluation window.

  4. Available-to-be-issued dateAll required internal approvals obtained

    This is the private company cutoff. Events after this date are not subsequent events for those statements.

  5. After available-to-be-issued dateStatements are distributed to lenders or owners

    Distribution does not extend the evaluation period if there is no revision or reissuance.

  6. After available-to-be-issued dateA material event occurs (for example, uninsured fire or customer bankruptcy)

    Outside the evaluation window. Do not adjust or disclose in those financial statements under ASC 855.

  7. Issued date (public filer context)SEC filer issues or files the financial statements

    For SEC filers, evaluation runs through the date issued rather than the available-to-be-issued date.

Key points

  • Available-to-be-issued means all required internal approvals are obtained; if bylaws require board approval, that approval date is the cutoff.
  • Distribution or mailing to users does not extend the evaluation period if there is no revision or reissuance.
  • Recognized events provide additional evidence about conditions that existed at the balance sheet date and require adjustment when within the evaluation period.
  • Nonrecognized events arise after year-end and are disclosed only if they occur before the cutoff and are material.
  • Non-SEC entities disclose the date through which subsequent events were evaluated and whether it is the available-to-be-issued or issued date.

How the exam traps you

  • Using the distribution date as the cutoff for a private company. Use the available-to-be-issued date. Distribution does not extend the evaluation period.
  • Adjusting or disclosing events that occurred after the available-to-be-issued date for a private company. Events after the cutoff are not subsequent events for those financial statements and are neither adjusted nor disclosed.
  • Leaving a settlement or customer bankruptcy unrecorded when it occurs before the cutoff and relates to a preexisting condition. Adjust year-end amounts when later evidence within the evaluation period confirms conditions existing at the balance sheet date.
  • Omitting the evaluation date disclosure in private company financial statements. Disclose the date through which subsequent events were evaluated and whether it is the available-to-be-issued or issued date.

6 more, each from a different angle

0 of 6 answered · 0 correct

Question 2

Oak Co. is a private company that does not file with the SEC. Its Year 1 financial statements are dated December 31, Year 1. On February 28, Year 2, management completed and approved the Year 1 financial statements for issuance to Oak's owners and lenders, and no further approvals were required. The statements were physically distributed on March 10, Year 2. Before distribution, Oak became aware of the following material events: 1. On January 18, Year 2, a major customer owing Oak $1.2 million at December 31, Year 1, filed for bankruptcy. The customer had been in severe financial difficulty before year-end and was 120 days past due as of December 31. 2. On February 14, Year 2, an uninsured fire destroyed one of Oak's warehouses. Assume the fire does not create substantial doubt about Oak's ability to continue as a going concern. Under U.S. GAAP, which treatment is most appropriate in Oak's Year 1 financial statements?
Hint

For each event, ask whether it provides evidence about a condition that existed at Dec 31, Year 1. Then confirm when a private (non‑SEC) entity's subsequent‑events evaluation period ends.

Question 3

Maple Co., a non-SEC private entity, has a December 31, Year 1 year-end. On February 28, Year 2, management completed a full set of GAAP financial statements in final form and obtained the last internal approval necessary to issue them; February 28 is the statements' available-to-be-issued date for subsequent-events purposes. The statements were not revised or reissued after that date, and they were sent to Maple's bank on March 15, Year 2. Two events occurred: 1. A product-liability case arising from a customer injury in November Year 1 was settled on February 20, Year 2 for $3.6 million. At December 31, Year 1, Maple had accrued $3.1 million for the claim. 2. An uninsured fire destroyed a warehouse on March 5, Year 2. The fire is material, but it did not create substantial doubt about Maple's ability to continue as a going concern. Assuming no other relevant events occurred, which is the best conclusion for Maple's Year 1 financial statements?
Hint

First identify the available-to-be-issued cutoff for a nonpublic entity, then decide which event provides evidence of a condition that existed at the balance-sheet date.

Question 4

Nolan Co., a private company that is not an SEC filer, has a December 31, Year 1 year-end. Management completed the Year 1 financial statements in final form on March 12, Year 2, and all internal approvals required to release the statements were obtained on that date. The statements were actually distributed to lenders and owners on March 25, Year 2. Two events occurred after year-end: 1. On January 20, Year 2, a major customer filed for bankruptcy. Nolan had been aware before December 31, Year 1 that this customer was in severe financial distress. 2. On March 18, Year 2, a fire destroyed one of Nolan's warehouses. Assume the fire was unrelated to conditions existing at December 31, Year 1. Under U.S. GAAP, which treatment is most appropriate for Nolan's December 31, Year 1 financial statements?
Hint

Separate the two issues: first decide the evaluation cutoff date for a private company, then decide whether each event relates to conditions that existed at year-end.

Question 5

On March 15, Year 2, Pine Co., a private company, completed all approvals required to make its Year 1 financial statements available to be issued. The statements were distributed to owners on March 25, Year 2, without substantive revision. The statements include the required disclosure of the date through which subsequent events were evaluated (March 15, Year 2). Each item below is material and none indicates substantial doubt about Pine's ability to continue as a going concern. 1. On January 20, Year 2, a customer who owed Pine $900,000 at December 31, Year 1 filed for bankruptcy. Information obtained after the filing indicates the customer's financial deterioration existed before December 31, Year 1. 2. On February 18, Year 2, Pine settled litigation arising from an alleged Year 1 product defect for $1,600,000. At December 31, Year 1, Pine had accrued $1,100,000 for the claim based on counsel's estimate. 3. On March 20, Year 2, an uninsured fire destroyed one of Pine's plants. Under U.S. GAAP, what is the required response in Pine's original Year 1 financial statements?
Hint

Identify Pine's subsequent-events cutoff (private companies: date available to be issued). For events within that window, ask whether each event supplies evidence about conditions existing at the balance-sheet date (adjust) or instead reflects conditions arising after the balance-sheet date (disclosure-only).

Question 6

North Co., a nonpublic entity, is preparing its December 31, 20X5 financial statements. Management completed the statements and made them available to be issued on March 14, 20X6. Assume the 20X5 statements were not later reissued. On March 10, 20X6, North settled a lawsuit arising from a product defect that existed before December 31, 20X5. The settlement amount differed materially from the liability North had accrued at year-end. On March 18, 20X6, a fire destroyed one of North's production facilities. The fire was unrelated to conditions existing at December 31, 20X5. Which treatment is most appropriate in North's December 31, 20X5 financial statements?
Hint

First determine the correct cutoff date for evaluating subsequent events for a nonpublic entity. Then decide which event relates to a condition that already existed at year-end.

Question 7

Redwood Co., a private company (not an SEC filer), has a December 31, Year 1 year‑end. Management completed and approved the Year 1 financial statements and made them available to be issued on March 12, Year 2; the statements were distributed to lenders on March 28, Year 2. Two material events occurred after year‑end: (1) March 5, Year 2, a major customer owing a December 31 receivable filed for bankruptcy due to financial deterioration that existed at December 31; (2) March 18, Year 2, a severe storm caused major uninsured damage to a plant and did not relate to conditions existing at December 31. The Year 1 statements will not be revised or reissued for any other reason. Under U.S. GAAP, which treatment of the December 31, Year 1 financial statements is most appropriate?
Hint

First identify the applicable subsequent‑event cutoff for a non‑SEC filer, then decide for each event whether it provides evidence of conditions that existed at year‑end.

Drill all 129 Subsequent events questionsMixed across every rule in the topic, so you have to spot which one applies. That is how the exam does it.

Common questions

What is the available-to-be-issued date for a private company under ASC 855?

It is when the financial statements are complete in GAAP form and all internal approvals are obtained. If board approval is required by bylaws, that board date is the available-to-be-issued date.

Do private companies have to disclose the subsequent events evaluation date?

Yes. Non-SEC entities disclose the date through which subsequent events were evaluated and whether it is the available-to-be-issued or issued date.

Do I disclose a major casualty that occurs after the available-to-be-issued date?

No. Events after the cutoff are not subsequent events for those financial statements and are not adjusted or disclosed under ASC 855.

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