SEC Disclosures With Respect To Fair Value Measurements

Originally published 2 April, 2008

In March 2008, the Division of Corporation Finance of the Securities and Exchange Commission sent a letter ¹ identifying a number of disclosure issues that public companies may wish to consider in preparing Management’s Discussion and Analysis (MD&A) for their upcoming quarterly reports on Form 10-Q.² The letter was sent to a number of public companies that had reported in their most recent Annual Report on Form 10-K a significant amount of asset-backed securities, loans carried at fair value or the lower of cost or market, and derivative assets and liabilities. In particular, the letter focused on Statement of Financial Accounting Standards No. 157, Fair Value Measurements (SFAS 157), and the related MD&A disclosure requirements concerning those fair value measurements.