Because accounting matters for which companies and their auditors seek the Office of the Chief Accountant’s (OCA's) views often involve complex fact patterns, OCA staff is able to provide the clearest guidance when companies provide a written submission outlining the factual details, accounting considerations, financial statement impact, as well as the disclosures expected to accompany the accounting. The staff believes the consultation process is best accomplished through written submissions on a named basis because of concerns that a clear understanding of the facts may not be accomplished solely through oral and/or anonymous communications. While the staff does accept oral inquiries, these inquiries generally involve broader, emerging issues that are not company or fact specific. As such, responses to no-name or telephone inquiries cannot be relied upon as positions of the staff.
If a company chooses not to consult on an accounting issue with OCA, the company may nevertheless encounter OCA during a review of their filing by the Division of Corporation Finance (DCF) or Investment Management (IM). The accountants in DCF and IM, not those in OCA, perform the reviews of the financial reporting and disclosure information contained in documents submitted to the SEC. The accounting staff in DCF or IM may have questions regarding technical accounting and disclosure matters discussed in a document and they will often consult initially with the Office of Chief Accountant within the Division of Corporation Finance (DCF-OCA) or the separate Chief Accountant's Office within the Division of Investment Management (IM-CAO) and then with OCA as to the answer. As such, OCA serves in a consulting role similar to the role of advisor or national office of an accounting firm.
Another way that an issue may find its way to OCA is if a company asks OCA to review an accounting decision made by DCF or IM. A company would initiate such a review by OCA by informing DCF or IM of its intention to request such a review. In cases of OCA reviews, companies do not need to make a submission directly to OCA in accordance with this guidance if all of the relevant information is contained in the comment letter responses from the company to DCF or IM, although a separate submission to OCA may serve to expedite the process.
Modified: Sept. 28, 2018