Comments, Notes and Footnotes

From NCCS Wiki

[edit] Permitting Written Explanations, Comments, Notes or Footnotes

The redesigned form seeks to eliminate the many attached statements and replace them with structured disclosures largely contained in schedules. What has been eliminated is the opportunity for a filer to explain the reason for amounts or text that has been recorded.

As a public disclosure document, it is important for filers to have an opportunity to explain its performance. Corporations are required to provide a detailed management, analysis and discussion (MDA) in its annual 10-K filing with the SEC. State and local governments must provide a MDA as part of their comprehensive annual financial reports (CAFRs).

We encourage IS to recommend that nonprofits be allowed to submit one or more written statements that are available to the public to clarify a particular field of information or elaborate more broadly. If e-filing is used, then it is not a problem to accommodate written explanations so long as they are entered as text and not as document images.

-- NCCS Comments on IS Comments (8/24/07)