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The SEC staff comments for liabilities, payables, and accrual estimates focused on:
  • the quantification of amounts accrued for contingencies, if any, and the possible loss or range of loss or disclosure about why an estimate cannot be made;
  • the timing of loss provisions;
  • the nature of the accounts payable and accrual balances and the appropriate disclosure of components of such balance; and
  • the accounting literature referenced to either include or exclude a liability from the accounting records.
Comment Examples
Guidance references
  • Please revise your disclosure relating to the stated claim in future filings to clearly disclose (i) the nature of any accrual you recorded, and (ii) an estimate of the reasonably possible loss or range of loss in addition to any amounts accrued or a statement that such an estimate cannot be made. Refer to ASC 450-20-50.
  • Explain the factors considered in determining the timing for recognition of the stated loss provision. Quantify for us your range of reasonably possible losses related to your exposure, and explain why you did not disclose such range pursuant to ASC 450-20-50-4.
  • Please explain the nature of the acquisition-related accruals. Please also explain the reason for the increase in the insurance accrual.
  • Please tell us how you determined it was not necessary to record a liability as of the period end date. Within your response, please reference the authoritative accounting literature management relied upon.
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