ASC 815-40-15-7 states: „An entity shall assess whether an equity-related financial instrument (or an incorporated feature), as described in paragraphs 815-40-15-5 to 15-8, within the meaning of this sub-theme and paragraph 815-10-15-74(a) is considered indexed using the following two-step approach: ASC 815-40 being a complex area of accounting – perhaps the most complex accounting area – it will be important: Keep first principles in mind. If time passes between the SAFE offer and the reference period, especially if additional bids have been made, the SAFE will likely have a different value and you should hire an evaluation specialist to help them. ASC 480-10-25-14 says in part: „A financial instrument. that the issuer must or can settle by issuing a variable number of its shares is considered a liability.