We believe that the selected financial data table required by Regulation S-K Item 301 should follow the transition provisions of the new leases guidance. Adjustments would only be required to those periods in the financial data table that correspond to the periods adjusted in the registrant’s financial statements included in the relevant filing. For example, a calendar year-end SEC registrant that is neither an emerging growth company nor a smaller reporting company will have a Form 10-K for the year ending December 31, 2019 that will include financial statements for each of the three years in the period ending December 31, 2019 and selected financial data for each of the five years in the period ending December 31, 2019. Assume that the entity elects to adjust comparative periods presented. January 1, 2017 is the beginning of the earliest comparative period presented in the financial statements. Accordingly, the registrant would only apply the new standard to 2019, 2018, and 2017 in the selected financial data table. The selected financial data for 2016 and 2015 are not considered comparative financial statements and therefore do not change the date of initial application of the new leasing standard for purposes of GAAP. The 2016 and 2015 information included in the selected financial data table will be prepared using the prior lease accounting model.
Similarly, if a reporting entity chooses not to adjust comparative periods, the four prior years in the selected financial data table would not be adjusted.
In either case, consistent with Instruction 2 to Regulation S-K Item 301, the registrant must provide disclosure regarding the lack of comparability of the data presented in the selected financial data table (if applicable and material).
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