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The SEC requirement for a specific balance sheet caption for commitments and contingent liabilities in S-X 5-02(25) applies only to SEC registrants. The guidance in ASC 450-20-S99-1 on the rate to be used to discount loss contingencies and in ASC 450-20-S99-2 on accruing legal costs is specific to SEC registrants. Based on limited authoritative guidance, we believe that private companies should consider applying these concepts as well.
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