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The staff has become aware of questions in practice regarding the application of ASR 26812 to equity securities with redemption features and other options . Since there has as of yet been no performance , we did not believe income recognition , in any amount , was appropriate , immediately upon the sale of the gift card . So , the five items I've discussed are the simplest things I can think of to ensure that financial statements and related disclosure are complete , accurate , and relevant for users : learn to use technology better , do n't forget education , reduce complexity , use judgment , and reduce disclosure overload . Many of the areas of GAAP that are considered overly complicated are areas that include detailed bright lines , exceptions to principles , or optional treatments . I was the host , however , and she was my guest , so off we went . While determination of the appropriate accounting is highly dependent on the form of the transaction , as I will discuss in a minute or two , perhaps the first question to ask is whose accounting am I addressing ? OK , so you're done creating your PDF document and have it looking just the way you want , but you want to send it off for a second opinion , or perhaps you need someone to sign-off on it . He also urged that ballets included in operas be choreographed so as to carry the plot forward . To qualify as a well-known seasoned issuer , a company must be eligible to file on Form S-3 or F-3 , and have at least $ 700 million in worldwide public float of common equity or have issued within the preceding 3 years $ 1 billion in non-convertible , non-equity , securities in a registered offering for cash . Perhaps the moral is that if you're an amateur , and you know in advance that you will never attain to professionalism , you should take care to avoid raising your standards - - the way I've always avoided developing a palate for fine wines so I wo n't drink my way into the poorhouse , moderate drinker though I am . However , following several inquiries from the staff it became clear that the registrant had entered into contractual agreements with several of the variable interest holders that effectively protected those holders from absorbing a significant amount of the entity 's variability . Using my previous example of a 10 % breakage rate , assume an entity issues $ 1,000 of gift cards in a certain period and has objective evidence to support that those gift cards would be redeemed on a pro-rata basis over the next twenty-four months . The front of the release lists the Commission staff that are involved in the program , so I encourage you to call them if you would like to volunteer .