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The date through which a reporting entity evaluates subsequent events differs depending on whether it is an SEC filer or a conduit bond obligor, or a non-SEC filer.
ASC 855 defines an SEC filer as follows.

Partial definition from ASC 855-10-20

Securities and Exchange Commission (SEC) filer: An entity that is required to file or furnish its financial statements with either of the following:

  1. The Securities and Exchange Commission (SEC)
  2. With respect to an entity subject to Section 12(i) of the Securities Exchange Act of 1934, as amended, the appropriate agency under that Section.

This definition specifically excludes financial statements of other reporting entities that are included in SEC filings, such as financial statements of acquired businesses or equity investees that are not otherwise SEC filers.
A conduit bond obligor is an entity that issues conduit debt securities, as defined in ASC 825.

Partial definition from ASC 825-10-20

Conduit Debt Securities: Certain limited-obligation revenue bonds, certificates of participation, or similar debt instruments issued by a state or local governmental entity for the express purpose of providing financing for a specific third party (the conduit bond obligor) that is not a part of the state or local government’s financial reporting entity.

If a reporting entity is a conduit bond obligor for conduit debt securities that are traded in a public market, the reporting entity is required to evaluate subsequent events through the date the financial statements are issued, similar to an SEC filer.
For an SEC filer or a conduit bond obligor, ASC 855-10-25-1A indicates that subsequent events are events or transactions that occur after the balance sheet date but before the reporting entity issues its financial statements. Voluntary filers should follow the same guidance as SEC filers. When a reporting entity has no registered securities but voluntarily files financial statements with the SEC, the filings should comply with all of the SEC’s requirements. A voluntary filer cannot choose which regulations to comply with in its filings.
Financial statements of acquired businesses or equity investees that are not otherwise SEC filers should evaluate subsequent events through the date that the financials are available for issuance, rather than up to the date the financial statements are issued.
An entity that files for an IPO does not become an SEC filer until its registration statement goes effective. As a result, a reporting entity that had previously reached the cutoff for recognizing subsequent events does not reopen and extend its subsequent events period when it files a registration statement with the SEC for an IPO.
The SEC staff provided its view as to when financial statements are considered “issued” in ASC 855-10-S99-2.

Excerpt from ASC 855-10-S99-2

...Generally, the staff believes that financial statements are “issued” as of the date they are distributed for general use and reliance in a form and format that complies with generally accepted accounting principles (GAAP) and, in the case of annual financial statements, that contain an audit report that indicates that the auditors have complied with generally accepted auditing standards (GAAS) in completing their audit. Issuance of financial statements then would generally be the earlier of when the annual or quarterly financial statements are widely distributed to all shareholders and other financial statement users or filed with the Commission. Furthermore, the issuance of an earnings release does not constitute issuance of financial statements because the earnings release would not be in a form and format that complies with GAAP and GAAS.

For non-SEC filers, ASC 855-10-25-2 indicates that subsequent events are events that occur after the balance sheet date but before the reporting entity’s financial statements are available to be issued. Financial statements are “available to be issued” when they are prepared in accordance with US GAAP and the reporting entity has obtained all necessary approvals (e.g., from management and the board of directors) for issuance.
For purposes of this chapter, the period from the balance sheet date to the date the financial statements are either issued (SEC filer or conduit bond obligor) or available to be issued (non-SEC filers) is referred to as the subsequent events measurement period. Figure FSP 28-1 summarizes the subsequent events measurement period by type of filer.
Figure FSP 28-1
Subsequent events measurement period by type of filer
Type of filer
Subsequent events measurement period
SEC filer, including voluntary filers
The period from the balance sheet date to the date the financial statements are issued
Conduit bond obligor for conduit debt securities that are traded in a public market
The period from the balance sheet date to the date the financial statements are issued
Non-SEC filer
The period from the balance sheet date through the date that the financials are available for issuance
Financial statements of acquired business or equity investees that are not otherwise SEC filers
The period from the balance sheet date through the date that the financials are available for issuance
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