re: FORM 20-F & EDGAR - No more OT than normal
>> Selected Forms Prescribed under the Securities Exchange Act of 1934: FORM 20-F
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D. How to File Registration Statements and Reports on this Form.
File with the Commission (i) three complete copies of the registration statement or report, including financial statements, exhibits and all other papers and documents filed as part of the registration statement or report, and (ii) five additional copies of the registration statement or report, which need not contain exhibits. File at least one complete copy of the registration statement or report, including financial statements, exhibits and all other papers and documents filed as part of the registration statement or report, with each exchange on which any class of securities is or will be registered. Manually sign at least one complete copy of the registration statement or report filed with the Commission and one copy filed with each exchange. Type or print the signatures on copies that are not manually signed. See Exchange Act Rule 12b-11(d) for instructions about manual signatures and the Instructions as to Exhibits of this Form for instructions about signatures pursuant to powers of attorney.
Registration statements and reports are filed with the Commission by sending or delivering them to our File Desk between the hours of 9:00 a.m. and 5:30 p.m., Washington, D.C. time. The File Desk is closed on weekends and federal holidays. If you file a registration statement or report by mail or by any means other than hand delivery, the address is U.S. Securities and Exchange Commission, Attention: File Desk, 450 Fifth Street, N.W., Washington, D.C. 20549. We consider documents to be filed on the date our File Desk receives them. We do not require foreign private issuers to file registration statements and reports under our Electronic Data Gathering and Retrieval System (EDGAR). We encourage you to use EDGAR, if possible, because documents filed through EDGAR are easily accessible by the public through the Commission's Internet Web site and through other electronic means. <snip> <<
This one's interesting:
>> The Political Dimension of Form 20-F: A German Perspective
Böckem, H.
ABSTRACT
At present, non-US companies who wish to list their shares at a US stock exchange, have to apply US-GAAP which is the only set of accounting standards admitted by the US Securities and Exchange Commission (SEC). Furthermore these companies are required to submit the so-called form 20-F set up by the SEC. Though the form contains basically disclosure requirements, it introduced a new statement into the accounting landscape: the reconciliation statements quantifying effects of the change from local GAAP to US-GAAP on net income as well as shareholders' equity. The majority of German companies chose to implement US-GAAP by issuing the reconciliation statement instead of setting up the entire accounts according to US-GAAP.
The first 20-F reconciliation "in the market", i.e. the Daimler reconciliation set up in 1993, caused an outcry in the financial community due to the entirely unexpected result of turning a (German GAAP) profit into a vast (US GAAP) loss. However, this result was mainly due to the change in the so-called "appropriated returned earnings", which was addressed to as a "bridge between the diverging accounting cultures" in the then Daimler accounts.
One would have expected that, given that in the meantime no basic change in German legislature regarding income measurement occurred, current reconciliations of German companies listing in the US would show comparable effects on the "appropriated returned earnings". Interestingly, e.g. for the SAP who was listed in the US in 1997, the reconciliation statement did not even mention such a position. Furthermore, the effects of the application of US GAAP as contained in the reconciliation were minor especially compared to the Daimler case.
In view of this anecdotal findings one may ask about the remains of the "bridge between the diverging accounting cultures" or, from a different - provocative - perspective, whether a bridging is still required to the extent exposed by the Daimler adjustment in 1993.
This question reveals a political dimension of the form 20-F which may have forced convergence of German accounting principles applied towards US GAAP required by the SEC in order to mitigate the reconciliation effects on income and equity. This process would amount to practice driven solution to the current issue of the international standardisation of accounting standards.
The paper explores the raised question on a political dimension of the SEC disclosure requirement by seeking evidence for convergence from 20-F forms of German companies. <<
- Eric - |
