13210.1 If financial statements as of a date on or after the date a component of the registrant has been disposed of or classified as held for sale are required in a registration or proxy statement, retrospective reclassification of all prior periods to report the results of that component in discontinued operations in accordance with ASC 205-20 is required. This guidance is applicable even where the filing incorporates by reference annual audited financial statements issued prior to the classification of the component in discontinued operations. The auditor's consent to incorporation of those financial statements in a registration or proxy statement is deemed a reissuance that requires consideration of the effects of subsequent events. Moreover, the financial statements prepared by management and included in the filing are required to comply with U.S. GAAP at the date of effectiveness or mailing, necessitating retrospective reclassification pursuant to ASC 205-20.

13210.2 Predecessor financial statements are required to be retrospectively reclassified to reflect the impact of a successor's discontinued operations. Registrants should contact the staff if unusual facts and circumstances may prohibit the company's ability to reclassify predecessor fiscal periods. (Last updated: 3/31/2010)