11410.1 Date of Initial Application

A calendar year-end registrant adopts ASU No. 2018-12 on January 1, 2023, with a transition date of January 1, 2021. In May 2023, 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, 2022, 2021 and 2020, as well as the quarters ending March 31, 2023 and 2022.

Item 11(b)(ii) of Form S-3 requires “restated financial statements” 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 that requires a material retroactive application. Does the reissuance of the registrant’s financial statements in accordance with Item 11(b)(ii) change the transition date to January 1, 2020 because it is the beginning of the earliest period presented?

No. The reissuance of the financial statements in Form S-3 accelerates the requirement to provide the financial statements for the years ended December 31, 2022 and 2021 with retroactive application, but does not change the transition date of the accounting standard.