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First , the guidance articulates twenty-six principles that should be present within an organization to achieve effective internal control over financial reporting , regardless of the organization 's size . Other consultants strengthened their policies by setting forth the maximum value of gifts that an employee could receive and , to ensure compliance , they imposed or better defined the requirements for employees to report the gift . 04-1 states that an intangible asset should be recorded apart from goodwill when previously granted rights to use the acquirer 's intangible assets are reacquired in a business combination . After all , public companies of all sizes can benefit from an increased focus on controls . Because there is a separate session at this conference devoted to internal control over financial reporting , I have n't gone into this area in any detail . At this point , we are not considering requiring XBRL , but we are gathering information and assessing its benefits to preparers , users , and regulators such as the Commission . I would now like to discuss the expected term assumption that is needed to use a closed-form option pricing model , such as the Black-Scholes-Merton model.5 When developing an estimate of expected term for input into a closed-form model , Statement 123R notes that there may be several different sources of information available , such as a company 's historical data , industry averages , or academic research.6 When the SAB was being developed , the staff understood that there were minimal sources of publicly available information that could assist companies in determining the period of time that an employee share option would remain outstanding . It always gave me a lift to go from an engineering office to a ballet class , to put off jacket and tie and put on practice clothes . In that example a company leases an asset from an entity that is entirely owned by a related party . Given that the PDF specification is and has always been freely available , the choice to build a widget to create , view or manipulate PDF documents has been contingent only upon the ability to meet financial and opportunity costs of development - - along with access to the requisite programming nous , of course . I would expect that an independent third-party that enters into this transaction would strive to maximize the transaction price received from the employer . And although it has been more than a few years since we've talked about new basis at this venue , with the recent uptick in the M & A market , the number of new basis issues addressed by the staff is on the rise . The extent to which management is comfortable basing its assessment on monitoring activities and other separate evaluations may depend upon the risks associated with a significant account , the relevant assertions involved , and whether there have been changes in the underlying process-level controls . 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 . Finally , one of the more frequent questions that we have been asked relates to the quantification of errors that arose from an inappropriate application of the shortcut method . As Russell Hodge spoke about last year at this conference , not everyone agrees on how to quantify errors that span more than one period . One of the general requirements of Statement 133 is that hedge accounting is only appropriate for hedging relationships that an entity expects to be highly effective in achieving offsetting changes in fair value or cash flows attributable to the risk being hedged.3 To meet this requirement , companies must assess the effectiveness of a hedging relationship both prospectively and retrospectively .