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Technology Stocks : MRV Communications (MRVC) opinions? -- Ignore unavailable to you. Want to Upgrade?


To: Johnnie Memmonic who wrote (16102)10/1/1999 6:42:00 AM
From: signist  Read Replies (1) | Respond to of 42804
 
What the SEC Does

The U.S. Congress created the SEC in 1934. Awakened by the Great Crash of 1929, our country decided that for capitalism
to flourish, we needed to protect investors from fraud and unfair sales practices. Since 1934, as our markets have grown and
changed, our laws and the regulations adopted by the SEC have kept pace with Wall Street. Although complex, these laws and
regulations boil down to a couple of very simple and common sense notions:

People who seek your investment dollars must tell you the truth about their businesses.

By contrast, SFAS No. 131 requires that a company provide

for each reportable segment quantitative disclosure of two basic

items - total assets and a measure of profit or loss. The new

standard defines neither segment profit (loss) nor assets.

Instead, management must determine what they will report based on

how they operate their business. In addition, companies must

disclose the following items for each segment, but only if

management includes them in measuring segment profit or loss:

* revenues from external customers;
* revenues from other operating segments;
* interest income;[20]
* interest expense;[21]
* depreciation, depletion and amortization;
* unusual items;
* equity in net income of equity method investees;
* income taxes;
* extraordinary items; and
* significant non-cash items other than depreciation,
depletion, and amortization.

A company also must disclose for each segment the amount of investment in

equity-method investees and total expenditures for additions to

long-lived assets if it includes the amount in its determination

of segment assets.[22]

The company must reconcile the totals of the reportable

segments' amounts for all of these listed items to consolidated

amounts. The FASB required more items to be disclosed per

segment under the new standard because analysts have long wanted

more information and most of the items required should be already

available in management reports.

Today we are amending our narrative and financial reporting

rules to conform their segment reporting requirements to the

FASB's revised accounting standards. We retain, however,

certain requirements relating to disclosure of principal products

or services and major customers that traditionally have differed

from the FASB standards.[23] We address below each of the rule

changes.[24]

1. Description of Business - Item 101

In the past, Regulation S-K Item 101(b)[25] required issuers

to disclose in the business description sections of documents

that they filed with the Commission financial information based

on GAAP's old "industry segment" standard. Under revised Item

101, registrants will report segment information in accordance

with GAAP's new operating segment standard.[26] Other changes to

Item 101 follow.

a. Principal products or services

Item 101 historically has required a discussion, by segment,

of the principal products produced and services rendered by the

issuer, as well as the principal markets for and methods of

distribution of each segment's products and services. On the

other hand, GAAP required, and continues to require, disclosure

of the types of products and services from which each segment

derives its revenues, without reference to principal markets and

methods of distribution. We continue to believe that information

relating to principal markets and distribution methods is useful

to investors; consequently we are retaining this provision.

Item 101 further requires registrants to disclose the

amounts of revenues from each class of similar products and

services based on quantitative thresholds. Specifically, the

issuer must state the amount or percentage of total revenue

contributed by any class of similar products or services that

accounted for 10 percent or more of consolidated revenue in any

of the last three fiscal years, or if total revenue did not

exceed $50,000,000 during any of those three fiscal years, 15

percent or more of consolidated revenue.[27] SFAS No. 131

requires disclosure of revenues from external customers for each

product and service or each group of similar products and

services unless it is impracticable to do so.

Because SFAS No. 131 requires disclosure regardless of

amount, unless impracticable, it appears that the new accounting

standard may require more disclosure than Item 101.

Consequently, we sought public comment as to whether we needed to

maintain the quantitative thresholds of Item 101(c)(1)(i).

Several commenters advocated eliminating the quantitative

thresholds and simply relying on the GAAP standard, which they

said implied a materiality standard for minimum disclosure. We

believe that SFAS No. 131 will result in disclosure of a range of

amounts of products and services, depending upon how a company

defines a class of related products or services. In fact, SFAS

No. 131 may require disclosure of amounts below the existing 10%

threshold of Item 101. We believe a clearly stated minimum

threshold for disclosure is desirable to eliminate any possible

ambiguity that may result from attempts to apply an unwritten

materiality threshold to small amounts of reportable revenues and

is in keeping with the 10% threshold used to report segments

under SFAS No. 131. We therefore have retained these Item 101

thresholds.
edgar.sec.gov


There seems to be a rule that allows confidential filings of information (if properly filed)

We may never find out details of our investment in NAC but IMO the financial gain or loss
should show up on the annual or quarterly.

John

Any informed person wishing to comment regarding disclosure responsibilities are welcome!