The fact of the investigation had been known for some time before events began snowballing this spring. In its filings, Dell typically dispatched the inquiry with a chunky paragraph calling it a formal investigation into “certain of Dell’s accounting and financial reporting matters,” accompanied by an internal investigation the results of which weren’t explicitly detailed.

Then Dell slipped a cryptic disclosure into an 8-K it filed with the SEC after 5 p.m. on April 1 — the Thursday before the three-day Good Friday market weekend. As subscribers to our FootnotedPro service know (we issued a report that afternoon), it read in relevant part:

“Dell has learned that, in connection with the resulting SEC investigation, several former employees of Dell have been contacted by the SEC staff and been provided with “Wells Notices.” … It is possible that other individuals have received or will receive such notices.”

Wells notices, of course, warn recipients that the SEC plans to sue, unless they can be convinced otherwise.

But then all was quiet on the disclosure front until the company’s quarterly report on June 10, when Dell laid it all out: Not only was the company itself negotiating a settlement of as much as $100 million (exactly what it turned out to be), but founder and CEO Michael Dell was negotiating to settle “alleged violations of the non-scienter (negligence) based fraud provisions of the federal securities laws,” and more. As if to reassure investors, the company added that a settlement “would not include any bar against his service as an officer and director of a public company,” and that the board would want him to stay chairman and CEO.

All well and good, but it prompts a discomfiting question: Just when did the company know that Michael Dell might be in hot water? And was there ever any question about whether he could continue to serve at the company’s helm?

These aren’t simply idle musings. We think it’s fair to say that Michael Dell represents more to the company than a name on the boxes it ships to customers. This is clear from reading about his role in the events detailed in the SEC’s lawsuit, as well as from his much-heralded return to the helm of the company in 2007, at the board’s request. (He had stepped aside in 2004, but remained chairman.) Nor is the $4 million that Michael Dell must pay trivial in the circumstances, as Floyd Norris argues on his blog.

In other words, Michael Dell’s fate in this case seems to have been pretty important to Dell and its shareholders. And yet, even a fairly dedicated reader of Dell’s filings would have had little clue that he was in the SEC’s cross-hairs until the 10-Q was filed. This despite the fact that the company’s own internal investigation was complete in fiscal 2008, and that Dell characterized discussions with the SEC as “ongoing” at least as far back as mid-March.

We’ve called Dell for a comment, but didn’t immediately hear back. We’ll update the post once we do.

All told, Dell’s shares are still down 10% since that cryptic after-hours disclosure on April 1, trailing the Nasdaq by a good 4.5 points. Would investors have been better off knowing more, sooner, even though there was more uncertainty about the outcome? It’s impossible to say for sure, of course, but as the matter at the heart of the SEC’s case suggests, we tend to think more disclosure is better.

Image source: D Sharon Pruitt via Flickr.

Last week the Associated Press published an article reporting that after Italian auto workers were told they couldn’t watch a match on company time, they went on strike a half hour before the game started. It also reported that business in Brazil “basically shuts down when its team plays,” and that Germany lost an estimated $8 billion in national productivity because citizens were glued to the games.

But surely other companies made money, right? Here are a few of the recent examples we found.

In an Earnings Release Conference Call on June 23, Nike’s (NKE) President and CEO, Mark Parker, stated in the transcript of the call:

“When you watch a World Cup match, whether you’re inside the stadium or in front of your TV, you can’t help but notice the bright orange and purple signature of our boots on the pitch. We developed four distinct silos of performance footwear, our lightest ever, and made them all the same vibrant color scheme — unheard of, until now. And that iconic product is just the very tip of the complete offense for World Cup we call Write the Future.”

PriceSmart, Inc. (PSMT), an “international membership shopping warehouse” with stores in 11 countries, reported in its July 9 quarterly report:

“The Company experienced strong sales in a number of merchandise categories as a result of the World Cup soccer tournament. For example, the Company experienced a 22% increase in sales in the electronics merchandise category in the quarter compared to the same quarter last year. While only one of the Company’s markets was in the tournament (Honduras), the World Cup generates significant interest across all of the countries in which PriceSmart does business and will likely have a continued positive impact on sales in the first part of the fourth fiscal quarter.”

Coca-Cola Hellenic Bottling Co., SA (CCH) recently disclosed that “…the World Cup also enables us to realize significant benefits from the unique marketing opportunities of one of the largest and most prestigious sporting events in the world.” Likewise, Brazilian Distribution Company (Companhia Brasileira De Distribuição) (CBD), which operates supermarkets, convenience, and department stores, reported that its sales spike in World Cup years.

Other companies used the World Cup as an anchor for marketing campaigns. Examples include Constellation Brands, Inc. (STZ), which reported in an exhibit to an 8-K that it built a sales promotion around the World Cup, as did Telecom Argentina SA (TEO), which ran a marketing campaign “offering prizes such as Ecosport trucks or trips to the World Cup.”

Banking giant Banco Bradesco (BBD) touted its special-edition “FIFA 2010 World Cup Visa Credit Card” as one of the choices that enabled it to offer its clients “the most complete line of credit cards and related services.”

And Mexico’s Grupo Televisa, S.A.B., (TV) disclosed that its subscriber base increased, as did the costs required to air “…exclusive transmission of 24 matches of the 2010 Soccer World Cup.”

Of course, regardless of how well a company fared, it’s inevitable that many companies will soon start trying to figure out how to profit from the 2014 tournament. And luckily for them (as opposed to the teams that compete), there can be lots of winners – not just one.

Image source: SouthAfricaLogue.com via Flickr

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Here’s the complete substance of the 8-K it filed toward the end of last week:

“On July 1, 2010, Arthur D. Smith, Ph.D., notified Ciena Corporation (“Ciena”) of his decision to resign as an officer and employee of Ciena and its subsidiaries effective as of July 31, 2010. Dr. Smith currently serves as Ciena’s Senior Vice President and Chief Integration Officer. Following his resignation, Dr. Smith will be entitled to certain compensation benefits, subject to certain conditions relating thereto, each as previously disclosed in Ciena’s Current Report on Form 8-K filed with the Securities and Exchange Commission on February 5, 2010.”

That’s it — “certain compensation benefits, subject to certain conditions relating thereto.” Translation: Dear shareholder, go look it up; we can’t be bothered to explain — either that, or we don’t really want you to know. You decide, but just leave us alone. (A press release attached to the filing was no help.)

Moreover, if you do dig up that Feb. 5 filing, it consists in its entirety of two paragraphs of 311 words, and no copy of the actual contract — despite the fact that most companies do file the documents when disclosing new compensatory contracts with top executives (which are by definition material agreements under Securities and Exchange Commission regulations). No doubt Ciena gets good legal advice, but assuming companies have some leeway here, is there really a good reason not to include it?

Especially since it seems to be a moderately peculiar arrangement, related to Smith’s role heading up the integration of acquired optical networking and carrier Ethernet assets: Smith could choose to resign at any time on or after July 31 this year, and in return for depriving the company of his continued services, would be entitled to “receive his current salary and benefits; to participate in Ciena’s incentive bonus plan; and to vest as to his outstanding equity awards in accordance with their existing terms” through Dec. 31 (unless he gets another job first). He also gets to keep medical, dental and vision benefits at the same time.

Any payments under those terms would offset a $350,000 lump-sum payment on Dec. 31 (or upon starting a new job) — the equivalent of a year’s salary — plus an annualized bonus payment under Ciena’s incentive bonus plan equaling 75% of his base salary,” presumably meaning another $262,500. In return, he can’t compete or try to hire Ciena employees for one year. In other words, Smith was bound to get some $612,500 in pay and severance between July 31 and the end of the year, whenever he left the company.

We’ve read enough employment and severance agreements to know this kind of disclosure leaves out a lot of potentially relevant details. For example, when it comes to the “general release of claims against Ciena and his compliance with a one-year non-competition and non-solicitation covenant,” exactly what kind of work can’t Smith do for a year? Which employees is he barred from soliciting? The implication is all of them, but might it be significant if that isn’t the case?

In the end, we have no view on whether Smith deserves this send-off. But it doesn’t seem like a monumental task for Ciena to provide a little more detail, or even the agreement itself. Failing to do so comes of very much like disdain for the company’s shareholders.

And it raises a real question: If the company has so little interest in clarifying a straightforward development like this one, should investors wonder about its other disclosures?

Image source: naunasse via Flickr

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So we took the opportunity to go back and dig a little deeper into some bank filings, and touch base with some of the accounting gurus we know. What we found, and put in the FootnotedPro report we published yesterday, is a simmering issue that’s going to be increasingly important to banks as they work through the aftermath of the financial crisis — banks ranging from giants like Wells Fargo (WFC) to smaller outfits like Zion Bancorp. (ZION) and Umpqua Holdings (UMPQ).

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The House passed its own Wall Street reform bill in December, of course, and now the two chambers must reconcile the language — inevitably a horse-trade in which some measures are stripped out, others modified and, on occasion, wholly new provisions inserted. But it’s safe to say that many of the Senate’s provisions, and quite possibly most of them, will make it into law in some form, in one form or another. (Of course, the House could also simply pass the Senate bill, sending it to President Obama’s desk.)

So without further ado, culled from the bill itself as well as supporting material posted on the Senate Banking Committee website, here are some provisions likely to make waves for companies, investors, securities lawyers and the rest of us who rummage around in corporate filings:

Say on pay: Perhaps most prominently, the bill would give investors an up-or-down vote on a broader range of executive pay than they currently have, albeit a non-binding vote. Companies have resisted similar, company-specific proposals made during the existing proxy process, but we hear that some directors are cheering it on — quietly, to avoid alienating management. After all, if investors have given the thumbs-up to a pay package, it gets harder to accuse the board of feathering management’s nest.

Proxy access: Another provision could make proxy battles more routine than dramatic novelty. It would give the SEC authority to let investors nominate directors using the proxy that companies distribute, instead of forcing them to launch an expensive proxy campaign with separate mailings if they want their own candidates elected. Investor advocates call it a powerful tool to make boards more accountable to shareholders (and therefore companies as well). Managers fret about environmental or union activists winning board seats and causing a ruckus. Much may depend on how the SEC implements any new requirement, but given that a similar provision is in the House bill, expect something along these lines to wind up in the final law.

Majority voting: The bill would also require directors in uncontested elections to receive a majority of votes cast to retain their seats. At least one recent version of the bill would require defeated directors to tender their resignation — and the board to accept it, unless it votes unanimously to keep the director on and makes its explanation public. Last year, the Council of Institutional Investors says, 45 companies kept 95 directors on their boards even after they failed to win a majority of votes.

Pay & governance grab-bag: Other provisions would require compensation committees to be made up of independent directors, with the authority to hire a consultant separate from management’s. Companies restating their financials would be required to claw back incentive pay from executives that was higher than it should have been because of the errors, a provision similar to one some large companies have already begun adopting. The SEC would also have to review its compensation-disclosure requirements — among other things, requiring a 5-year comparison of executive pay to stock performance, which “may include a graphic representation of the information required to be disclosed.” A new Investment Advisory Committee would give investors a formal voice within the SEC, offering advice on regulatory practices and priorities.

Corner-office qui tam: Health-care companies and defense contractors have had to worry about whistleblower lawsuits for years, thanks to laws that give plaintiffs in successful “qui tam” lawsuits a cut of the recoveries in cases over defrauding the government. Now more companies could face similar risks under a provision that would allow those reporting securities violations to collect as much as 30% of any funds recovered, according to a bill summary posted on the Senate Banking Committee site.

Good for the gander: The banking committee’s bill summary suggests CFOs everywhere may get to experience a little schadenfreude as they prepare the 10-K each year: One provision would require the SEC to suffer through its own annual review of internal supervisory controls, and orders up a study of “SEC management” from the Government Accountability Office.

Image source: scott*eric via Flickr

Validus Holdings Ltd. (VR), a reinsurance company (it sells insurance protection to insurance companies) that provides coverage to property and shipping industries, filed an 8-K and press release on April 30 with loss estimates, one of the few companies so far to put a dollar figure on the spill.  It stated: “Based on an industry loss estimate of $1.3 billion, Validus expects its losses to be in the range of $38 million to $45 million. These loss estimates are net of reinstatement premiums, reinsurance, retrocessional and other recoveries.”  Validus added that the loss is “well within [its] expected large loss load for the quarter and the company has additional reinsurance in place if the ultimate industry loss increases above the current estimate.” It added, though, that its actual losses might “vary materially” from its estimates.

Companies that depend on tourism for revenues are also bracing for losses.

For example, in the 10-Q that West Marine, Inc. (WMAR) filed on May 12, the company, which sells boats and boat-related products and services, said that the oil spill in the Gulf of Mexico may have a “substantial impact on boating usage in the area.”  The company has more than 300 stores in 38 states, Canada, and Puerto Rico, and it appears from its website that about a third of those stores are located in states with Gulf coastlines.  West Marine explained that “As we are entering into peak boating season, the continuing underwater leaks and resulting oil spill may have adverse effects on our results of operations by reducing demand for our marine products….”

Grocery chain Winn Dixie Stores, Inc. (WINN) filed a 10-Q on May 10 which noted that revenues in the fishing, tourism, and shipping industries are likely to suffer. Winn Dixie’s filing stated:  ”We have stores in the Gulf Coast region, on the west coast of Florida and the Florida Keys. A decrease in tourism in these areas as a result of the spill may have a negative impact on our sales in these locations.”  Winn Dixie is also trying to reassure customers that the seafood it sells is safe.  Its website now has a page with a letter to customers stating, in part:  ”We understand that you may have concerns due to the recent oil spill, so we want to remind you that, as always, all of our seafood is checked by local inspectors before it comes into our warehouse. It is then checked again by our local Seafood Associates before it is placed on display for sale.”  Given today’s news that tar balls are now washing up on Florida’s shores (although tests are underway to confirm that they originated from the BP spill), it seems likely that the accident will harm a wider geographical area than BP first predicted, and that Winn Dixie’s concerns are justified.

Hibernia Homestead Bancorp (HIBE), a bank that serves the New Orleans metropolitan area, filed a 10-Q on May 17 which reported that the company is currently evaluating the “potential effects” on its customers.  It added, “The future effects of the oil spill could impact the Company and our earnings, but until more is known about the magnitude of the situation, it is premature to reasonably determine the impact on the Bank’s loan portfolio.”

BP filed another 6-K update on the oil spill just yesterday to report its efforts to stop the leak, drill “relief wells” (which it says will take “some three months to complete from the commencement of drilling”), and contain and recover the oil that is spreading.  It states that over 650 vessels are involved in the recovery effort, that it has recovered 6.3 million gallons of “oily liquid”, and that

“…over 19,000 personnel from BP, other companies and government agencies are currently involved in the response to this incident.  So far 15,000 claims have been filed and 2,600 have already been paid.  BP has also received almost 60,000 calls into its help lines.”

Clearly, the oil spill will continue to have a great impact on the Gulf area, its businesses, and its residents.  It’s also apparent that the claims for losses will be both numerous and costly.

From time to time, we’ll continue to watch as companies update their filings and disclose how the oil spill is affecting them.

Image source: IBRRC via Flickr

Since the spill occurred, BP has filed nearly two dozen separate 6-Ks to provide regular updates on the company’s efforts to contain the oil spill and mitigate its damages. (We don’t generally write about 6-Ks, so it might help to know that foreign companies use them to report material disclosures; they’re similar to the 8-Ks that U. S. companies file.)

In a May 10 filing, BP stated:

“Provided BP can stem the well and clean the spill within a reasonable time, the company has adequate liquidity and financial headroom to meet immediate costs, in our view. However, it is still too early to estimate with any degree of confidence the full future impact on BP from the spill, as the causes of the incident have not yet been fully investigated. Litigation involving the well’s owners and various contractors … may take several years to play out. The effectiveness of BP’s actions to mitigate the environmental impact of the spill will be important in the final assessment of the incident and any long-term reputational damage could be significant.”

But what about other companies that depend on the Gulf of Mexico for their success?

To answer that question, we researched numerous SEC filings submitted by companies other than BP. Although many companies say it’s too early to predict their damages, it’s clear that companies are bracing for a variety of losses.

In this first of two posts related to the spill, we’ll look at some of the companies within the oil sector.  Later today, our second post will include filing disclosures from companies in other sectors.

A number of companies warned that the spill could prompt new regulations, with unpredictable results. Houston-based Noble Energy, Inc. (NBL) filed a quarterly report on April 29 noting simply that “we cannot predict how government agencies will respond to the incident or whether changes in laws and regulations concerning operations in the Gulf of Mexico, including the ability to obtain drilling permits, will result.”

Anadarko Petroleum Corp. (APC) filed a 10-Q on May 4 that also expressed concern about the impact of new regulations, including calls from government officials and federal agencies for increased inspections of deepwater drilling operations in the Gulf.  That, and other regulatory changes, the company said:

“…may result in substantial cost increases or delays in our offshore exploration and development activities, which could materially impact our business, financial condition and results of operations.”

In the quarterly report that Marine Petroleum Trust (MARPS) filed May 17, the company – which hasn’t been directly affected by the spill yet – stated that it may be adversely impacted as the oil slick spreads, as well as from new, more stringent regulations.

Likewise, in the 10-Q that ATP Oil & Gas Corp. (ATPG) filed on May 10, the company expressed concern that the government’s moratorium on offshore drilling permits, which is currently set to expire May 28, may be extended.  Stating the obvious, ATP Oil & Gas added, “A prolonged interruption in our drilling or production operations would adversely affect our financial position, results of operations and cash flows.”

Hercules Offshore, Inc. (HERO), which provides offshore contract drilling, liftboat and inland barge services, added in the 10-Q it filed April 30 that the spill could damage its vessels or delay its operations.  That potential damage and/or delay, along with potential regulatory changes, “…could reduce our revenues and increase our operating costs, resulting in reduced cash flows and profitability and could impact compliance with our Credit Agreement.” In the more recent 8-K that Hercules filed May 13, the company said it has three jackup drilling rig operations that fall within limited exceptions to the moratorium that should be able to complete their work during the moratorium period. However, it doesn’t expect new contracts until after the moratorium is lifted. It then stated: “If the moratorium is extended beyond May 28, 2010, it could also affect our other jackup drilling rigs in the U.S. Gulf of Mexico regardless of contract status. We believe that some of our contracts may not be fully permitted, or may not be fully permitted for the entire duration of the contract.”

Newpark Resources, Inc. (NR), a diversified oil and gas supplier, filed an S-3 on May 12 to state that its Gulf Coast customers “may possibly be forced to curtail or cease operations in the areas impacted by the spill, resulting in less demand for our drilling fluids and waste disposal services.”  The company said it might also have to suspend operations and could have trouble delivering its products by barge.  ”Either of these events could potentially result in a reduction in revenues or an increase in our costs,” the filing stated.

And finally, Blue Dolphin Energy Co. (BDCO) filed a 10-Q on May 17; in addition to the increased costs and potential delays that may come with increased federal regulations, the company noted that increased regulations “may lead to increased difficulties obtaining insurance coverage on economically manageable terms.”

This afternoon, we’ll examine how other companies outside the oil industry are being affected by the BP oil spill.  Please check back with us for that report.

Image source: uscgd8 via Flickr

Done right, companies figured at the time, it offered particularly attractive tax consequences, and some companies were less than transparent in their disclosures. The executives, meantime, could borrow against the policies, repaying the loan out of the proceeds at death, effectively extracting the cash without pesky tax consequences.

Then along came Sarbanes-Oxley with its prohibition on company loans to top executives, plus a push by the U.S. Treasury Department to tell the world that, yes, a free life-insurance policy has value and counts as taxable pay. Almost overnight, split-dollar deals started vanishing from the filings.

But not completely. Witness American Greetings Corp. (AM), the century-old “retailer of innovative social expression products that assist consumers in enhancing their relationships.” (And here we thought it was a greeting-card company that had come up with a prominent Web strategy.) The company had promised its chairman, the now 70-year-old Morry Weiss, a $30 million death benefit through a split-dollar arrangement. Now, some seven years after the passage of Sarbanes-Oxley, they’re paying him to give it up. To quote the company’s proxy, filed Thursday:

“After receiving legal advice from independent counsel that Mr. Weiss could have contractual claims against the company for early termination of the split dollar life insurance agreement, the Compensation Committee determined it was in the best interests of the company to resolve such claims promptly.”

To determine a fair payment, the company’s directors considered, among other things, “the cost of Mr. Weiss obtaining a comparable life insurance policy, the tax consequences of receiving additional compensation from the company, and the impact of the termination of the split dollar life insurance program on Mr. Weiss’s overall compensation package.”

That equation has yielded about $4.7 million for Weiss since February 2009. (The trust that was to benefit from the insurance policy paid American Greetings the cash value of the policy when the deal was unwound last year, some $1.2 million, though it’s not clear from the filings how that figure relates to the payments Weiss received.)

We’d love to think the company gave Weiss a big ol’ stack of those slim cards designed to hold money with a stack of Ben Franklin’s peeking out. These days, though, he probably got an e-card instead.

Image source: cmpalmer via Flickr

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In the filing, which was significantly longer than the 2008 10-K, the company disclosed that total compensation for one of its directors was over $600,000 in 2009. Eight other directors collected more than $300,000 and two received a little less than $250K.  Kenneth Frazier, Merck’s Executive Vice President of Global Human Health and a new bee to Exxon’s Board of Directors last year, made the most: $614,283, though to be fair, the bulk of that was in stock awards as opposed to cash compensation. While the other 10 directors took home $201,263 in stock awards, Frazier’s award was valued at $554,280. The footnotes reveal Frazier received a one-time grant of 8,000 restricted shares upon being first elected to the Board in May 2009. The valuation of this award is based on a market price of $69.29 on the date of grant, which is actually higher than Exxon stock is currently trading at.

Our find on Exxon’s director pay was just one of a few gems buried in last weeks’ filings. Other companies that fueled up their director’s pay in 2009 were Baker Hughes (BHI), Brocade Communications (BRCD) and Arkansas Best (ABFS). Directors at Brocade and Baker Hughes received more than $200K, while Robert Young of Arkansas Best pocketed $280K. Young’s perquisite value included personal use of the company’s aircraft and a hunting lodge, an administrative assistant, a nominal gift related to business activities and a Christmas gift from the Company.

This post was written by footnoted intern Kristen Scholer, who is a junior at Northwestern University.

Last month, the SEC issued some guidance on this topic. Still, there’s no formal rules as of yet. But with 10Ks flowing fast and furious, we wanted to take a closer look at what companies are saying.  To do that, we took a digital “snapshot” of one day’s filings that referred to greenhouse gas emissions.

Twelve of the 13 companies referred to one or more of the following:  the public discussion about greenhouse gases, recent findings published by the EPA, pending legislation, debates over a cap and trade system and carbon taxes, policies in Europe and Canada, and – almost always – a statement that the passage of new greenhouse gas laws would probably increase operating costs.

However, one filing was dramatically different – the 10-K filed by Coca-Cola Enterprises, Inc. (CCE), the company that produces, distributes, and markets products of The Coca-Cola Company.

In the context of an initiative called “Commitment 2020,” the company promises that it will invest in energy efficient technologies that improve company facilities and reduce carbon emissions.  On page 21, it states:

“As part of our commitment to Corporate Responsibility and Sustainability (CRS), we have calculated the carbon footprint of our operations in each country where we do business, developed a GHG emissions inventory management plan, and set a public goal to reduce our carbon footprint by 15 percent by the year 2020, as compared to our 2007 baseline.”

The company acknowledged that this plan involves risks:  It might not achieve its goals, the financial investment might not yield the desired returns, and/or a failure might harm the company’s reputation.

For the rest of us, it’s often a challenge to determine whether a company’s claims are green, or greenwashing.

Admittedly, we’re relying on the statements in the annual report; but there are several passages in the filing that seem to support the company’s claims.  Efforts range from introducing a plastic bottle at the current Winter Olympics that is constructed partly from plant materials, to plans to remediate any environmental hazards, to the measurable goals for five areas that are part of the Commitment 2020 plan (p. 29):  “water stewardship, sustainable packaging/recycling, energy conservation/climate change, product portfolio/well-being, diverse and inclusive culture.”

That’s a lot to accomplish in 10 years, but – by setting its own strategy rather than waiting for Congress to pass regulations and the SEC to require additional disclosure – CCE might have an interesting competitive edge.

Image source:  Scientific American