Backdating and spring loading stock options
This letter expresses only the views of the Office of the Chief Accountant on accounting issues related to Opinion 25, and its limited application should not be extended by analogy or relied upon in any other circumstances.
Nonetheless, some companies that utilized the practices described above have asserted that the measurement date occurred before the required granting actions were completed because all option terms and recipients were final and known at an earlier date, and the completion of required granting actions represented only an administrative delay, rather than a period during which any of the terms of the award remained under consideration or subject to change.
Many other companies have announced that they are currently looking into their past practices related to the granting of stock options.
The Office of the Chief Accountant has prepared this letter to discuss certain of the existing accounting guidance related to grants of stock options.
However, we understand that some companies have accounted for their option grants using a measurement date that is other than the date at which all required granting actions have been completed.
Two such examples that we have become aware of are as follows.It should be noted that the views presented herein are limited to the ramifications of these questions to the financial statements (including the footnotes thereto), and that this letter does not address how these questions might affect disclosures outside of the financial statements or the circumstances under which any of these practices could violate laws or regulations.