Skip to content

SEC Staff Accounting Bulletin No. 99 (SAB 99)

Definition

A 1999 SEC interpretive release stating that the traditional five-percent quantitative threshold for materiality is not a safe harbour and that qualitative factors can make a numerically small misstatement material. Widely applied by auditors and enforcement authorities in the United States.

Year issued
1999
Issuing body
US Securities and Exchange Commission
Core point
Five-percent quantitative threshold is not a safe harbour
Adds
Qualitative factors can make a small misstatement material
Jurisdiction
United States

Common questions

Why did the SEC feel a need to issue SAB 99 rather than let the five-percent rule of thumb stand?+

Companies and auditors had been treating a misstatement below roughly five percent of net income as automatically immaterial and therefore not worth correcting, and the SEC wanted to close that loophole because a small misstatement can still mislead investors depending on its nature and context.

What kind of qualitative factor can make a numerically tiny misstatement material under SAB 99?+

Examples include a misstatement that turns a loss into a profit, one that affects whether a company meets analyst expectations or a loan covenant, or one that conceals an illegal payment, since these change how a reasonable investor would view the company regardless of the dollar amount involved.

Is SAB 99 binding law, and does it apply outside the United States?+

SAB 99 is SEC interpretive guidance rather than a statute or regulation with independent legal force, but auditors and the SEC's own enforcement staff rely on it heavily in US materiality assessments; other jurisdictions apply their own accounting standards' materiality concepts, which are similar in spirit but not identical in wording.

Related terms

Cookie-Jar Reserve
An accounting reserve built up in a period of strong earnings by overstating provisions or allowances, then released in a later period...
Earnings Management
The use of accounting choices, estimates, and timing decisions within the bounds of GAAP or IFRS to influence reported earnings. Permissible in...
Financial-Statement Fraud
Intentional misstatement or omission in financial reports to deceive users of those reports, typically to inflate earnings, understate liabilities, or maintain a...
Materiality
The threshold at which a misstatement or omission would influence the decisions of a reasonable user of the financial statements. Assessed both...
PFUTP Regulations 2003
The Securities and Exchange Board of India's Prohibition of Fraudulent and Unfair Trade Practices (Relating to Securities Markets) Regulations 2003. The primary...

Explained in

Your journey to becoming a forensic professional starts here.

Practice with mock tests, learn from structured notes, and get your questions answered by a global forensic community, all in one place.