Question
A calendar year-end registrant adopts the new leasing standard on January 1, 2019, with an initial application date of January 1, 2017. In May 2019, the registrant files its first quarter 10-Q, which reflects the adoption of the new standard. The next month, the registrant files a registration statement on Form S-3 that includes financial statements for the years ending December 31, 2018, 2017, and 2016, as well as the quarters ending March 31, 2019 and 2018.

Item 11(b)(ii) of Form S-3 requires retrospective revision of the pre-event audited financial statements that were incorporated by reference in the Form S-3 to reflect a subsequent change in accounting principle. Does the reissuance of the registrant's financial statements change the date of initial application to January 1, 2016 because it is the beginning of the earliest comparative period presented?

Answer
No. The reissuance of the financial statements in Form S-3 accelerates the provision of the retroactively restated financial statements for the years ended December 31, 2018 and 2017, but it does not change the date of initial application.