SOX walkthrough · FG · FY25 · 2 of 3

Accounting policies, for a finance newbie

How the company decides the rules for counting money, notices when FASB changes the rules, and checks the published financial statements still match US GAAP.

Start here

If journal entries are the diary pages, policies are the grammar. This walkthrough is External Reporting’s job: make sure the company uses US GAAP, notices new standards, and that the published statements + footnotes match those rules.

Two halves: (1) update and monitor policies, (2) line the financial statements up with standards and disclosures.

Catching new accounting rules

External Reporting sits on the FASB action-alert email list. New ASUs go into an Excel tracker with effective dates. Someone does a first-pass “does this even apply to us?” Significant ones get a working group. Every year: an ASU memo + the tracker is compared to everything FASB released.

FG07 is the key control that they did not miss a new standard (LSPM-FG01). VP & Corporate Controller also reads the tracker against what they heard in working groups. Evidence = approval email.

Working groups

If a standard is big (revenue, leases, CECL), controllers of the affected units staff a group: timeline, which bits of the rule matter, which policy elections to take. Small / almost-due changes: one External Reporting memo plus “what did similar companies do?” No elections were taken this period, the narrative says.

Significant / unusual items

Definition here: outside normal business, or something management almost never accounts for. Corporate Controller hears via CFO, because they sign the deal, or in biweekly senior-finance 1:1s. Risk LSPM-FG04: a big unusual thing never makes it into the statements. Later, the 10-K Review Group + FG07 is what they rely on to catch that.

The recurring “are we still doing this right?” memos

Hard / confidential topics go to more senior people. Most memos are reviewed by VP & Corporate Controller (investments-without-fair-value memo can stay with Treasurer/Senior Director unless it changed).

CodeCadenceWhat the memo is asking
TEN11QuarterlyWhat are our operating segments? (ASC 280)
TEN06YearlyEach subsidiary: local currency or USD? Translation (ASC 830)
RB03YearlyInvestments: equity method? fair value? a VIE? (ASC 321 / 323)
TJN01QuarterlyRelated parties and deals that must be disclosed (ASC 850)
NBN01QuarterlyAny sign a long-lived asset is impaired? recoverability test?
NBN06YearlyAre reporting units still right? (ASC 350)
NBN10YearlyIs goodwill still worth what we say?
UA12QuarterlyCan the company keep operating? going-concern disclosure? (ASC 205)
MB02QuarterlyStock-based pay: options, RSUs, DSUs (ASC 718)
HJN01Policy guidePlain-English revenue recognition (ASC 606)

Estimates (LSPM-FG02)

Big numbers that are guesses (litigation accruals, valuations). High-value ones get more signatures. Ugly ones hire a third-party valuator (example in the doc: KPMG on convertible debentures). Litigation: quarterly sit-down with legal. ARM committee hears the key estimates each quarter.

Draft financial statements and footnotes

  1. Accounting Operations consolidates numbers.
  2. External Reporting fills the external-filing template and writes notes. They use DisclosureNet to spy on peer footnotes and new rules.
  3. New standard → draft the footnote early, show Controller + CFO, put it in Note 1 plus its own note if needed.
  4. Quarterly disclosure checklist TEN02.
  5. Treasurer / Senior Director of Financial Reporting reviews notes vs required disclosures.
  6. 10-K Review Group (CFO, Controller, IR, internal + external counsel) gets a draft before ARM. Then a “page flip” call: screen-share, page by page, focus on what changed. Canadian + US securities lawyers check filing rules.
  7. ARM comments → blackline back to the Review Group.
  8. CFO email is the final “file this” (FG07). That same FG07 is the key control for “statements presented properly” (LSPM-FG03) and “unusual items not omitted” (LSPM-FG04).

Other pages: journal entries · reconciliations · Session 1 close

Original document

SOX Walkthrough Narrative — Accounting Policies — FY25.pdf Open PDF Download

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