Turns out, everyone is befuddled by the definition of "nonpublic entity":
The Financial Accounting Standards Board has added a new project to its agenda to re-examine the definition of a “nonpublic entity,” as part of its efforts to reach out more to private company constituents. […] The decision by FASB chair Leslie F. Seidman to add the new definition project to the board’s agenda stems from comments FASB received asking for a clarification of the existing definitions. FASB has also received ongoing questions about which definition of a nonpublic entity was being used in various projects.
FASB Re-examines Definition of ‘Nonpublic Entity’ [AT]