I thought that it might come from Carol Stacey, chief accountant for the Division of Corporation Finance, at the AICPA SEC Conference I mentioned on Friday. And she did mention it, without giving a specific date for the release. The important part: while firms might not be expected to restate ALL prior years. For the years prior to a restatement, a schedule will be provided in the restated financials showing the year-by-year difference between the reported compensation and the correct amount of compensation, including tax effects and the effects on the opening balance of retained earnings, as far back as the restating goes.
That would actually be a case of “less is more.” If Home Depot was going to restate all the way back to 1981 (I know their amounts weren’t all that material; it’s the extent that’s interesting), I think analysts would rather not plow through 25 years of restated annual results to get the corrected numbers. The summary would do just fine.
While we wait for the guidance to appear, I invite you to download our list of firms that have mentioned investigations of option granting practices in their filings, or have been mentioned in the news. It’s a list (in Excel file form) we’ve compiled of the more than 200 firms.
Some interesting attributes: 45 of them are S&P 500 companies. In 2005, 46 of them engaged in acceleration of options in order to beat Statement 123R’s expense treatment requirements. There are 37 that have had executive departures. And the average market cap is $4.7 billion.