I was working on the finishing touches for the process of uploading the initial CAM_FEE data – which should be live in the next 10-12 hours. I was specifically agonizing on the value we should use for the AUFEEYEAR field. There is such inconsistency in how SEC registrants refer to their fiscal years and thus how it the data is reported in their filings.

As part of my research I decided to run a search for the phrase ‘FISCAL 2020 and 2019’. I had forgotten that when we search using words that are also search operators (and/or/not) it is necessary to append a tilde (~) to the operator that we want to use as a search term. Without the tilde the term is treated as an operator. The original search phrase returns all documents with the phrase FISCAL 2020 and the number 2019 somewhere else in the document. However, with the tilde (FISCAL 2020 and~ 2019 my search returns exactly what I was searching for (all documents with the phrase ‘FISCAL 2020 and 2019’

To illustrate the issue I am concerned about – here is an image from the 10-K/A filed by TECH DATA CORP on 5/21 (their FYE is 1/31).

Williams Sonoma’s FYE is 1/29. However, in their audit fee disclosure they describe the fee payment for their most recent fiscal year end as payment for FISCAL 2019.

Since we need to link the audit fee disclosure and the audit opinion and since the audit opinion is included in a 10-K filing that has the balance sheet date as the last date of the fiscal year – the AUFEEYEAR value needs to be the YEAR from the balance sheet date. I hope that is not confusing but that gives us the most robust way to track the data between the two filings DEF 14A and the 10-K. If we didn’t do this then we could have some 1/31 filers with the AUFEEYEAR value reported as 2019 (see William Sonoma) and others with the value 2020 (TECH DATA CORP).