FASB Comment Letter Archive
The Financial Reporting Executive Committee ( FinREC), formerly known as the Accounting Standards Executive Committee (AcSEC), has prepared the following positions addressed to bodies having authority over accounting and financial reporting standards.
Accounting Standards team members help develop comment letters to communicate the views of the FinREC on financial accounting and reporting proposals issued by standard setters, such as FASB, GASB, and the IASB.
Letters to FASB
2013
Accounting Standards team members help develop comment letters to communicate the views of the FinREC on financial accounting and reporting proposals issued by standard setters, such as FASB, GASB, and the IASB.
Letters to FASB
2013
- November 27, 2013, comment letter on the Financial Accounting Standards Board’s Exposure Draft—Insurance Contracts
- October 18, 2013, comment letter on the Financial Accounting Standards Board’s Proposed Accounting Standards Update—Consolidation (Topic 810): Applying Variable Interest Entity Guidance to Common Control Leasing Arrangements (a proposal of the Private Company Council)
- October 14, 2013 comment letter on FASB’s May 16, 2013, Exposure Draft (ED) of a proposed Accounting Standards Update (ASU) Leases (Topic 842)
- October 2, 2013, comment letter on the Financial Accounting Standards Board’s (FASB) August 7, 2013, Proposed Accounting Standards Update, Definition of a Public Business Entity - An Amendment to the Master Glossary
- September 24, 2013, comment letter on the Financial Accounting Standards Board’s (FASB or Board) June 26, 2013 Invitation to Comment, Disclosure of Uncertainties about an Entity’s Going Concern Presumption
- August 29, 2013, comment letter on the Private Company Council’s Proposed Accounting Standards Update (ASU), “Derivatives and Hedging (Topic 815) – Accounting for Certain Receive-Variable, Pay-Fixed Interest Rate Swaps.”
- August 29, 2013, comment letter on the Private Company Council’s Proposed Accounting Standards Update (ASU), “Intangibles – Goodwill and Other (Topic 350) – Accounting for Goodwill.”
- August 29, 2013, comment letter on the Private Company Council’s Proposed Accounting Standards Update (ASU), “Business Combinations – Accounting for Identifiable Intangible Assets in a Business Combination (Topic 805).”
- July 8, 2013, comment letter on FASB and PCC April 15, 2013, Invitation to Comment, Private Company Decision-Making Framework—A Guide for Evaluating Financial Accounting and Reporting for Private Companies (the guide)
- June 11, 2013 FASB comment letter on the Proposed Accounting Standards Update (ASU), Recognition and Measurement of Financial Assets and Financial Liabilities
- May 31, 2013, comment letter on Financial Instruments—Credit Losses
- December 11, 2012, comment letter on FASB's Invitation to Comment (ITC), Disclosure Framework
- October 8, 2012, comment letter on the FASB Exposure Draft of a Proposed Accounting Standards Update, Financial Instruments (Topic 825), Disclosures about Liquidity Risk and Interest Rate Risk
- October 4, 2012, comment letter on the FASB Accounting Standards Update (ASU), Presentation of Financial Statements--The Liquidation Basis of Accounting
- April 19, 2012, comment letter on the FASB Accounting Standards Update (ASU), Intangibles—Goodwill and Other (Topic 350) - Testing Indefinite-Lived Intangible Assets for Impairment
- March 13, 2012, comment letter on the FASB Exposure Draft of a Proposed Accounting Update (ASU), Revenue from Contracts with Customers
- February 14, 2012, comment letter on the FASB Accounting Standards Update (ASU), “Consolidation (Topic 810): Principal versus Agent Analysis”
- February 14, 2012, comment letter on the FASB Accounting Standards Update (ASU), “Financial Services—Investment Companies (Topic 946): Amendments to the Scope, Measurement, and Disclosure Requirements”
- February 14, 2012, comment letter on the FASB Accounting Standards Update (ASU), “Real Estate—Investment Property Entities (Topic 973)”
- December 19, 2011 comment letter on the FASB Proposed Accounting Standards Update, Technical Corrections
- June 3, 2011, FinREC comment letter on FASB Accounting Standards Update (ASU) Intangibles—Goodwill and Other (Topic 350) - Testing Goodwill for Impairment
- April 29, 2011, FinREC comment letter on the FASB Exposure Draft of a Proposed Accounting Update (ASU) Balance Sheet (Topic 210) - Offsetting
- March 30, 2011, comment letter on the Supplementary Document Accounting for Financial Instruments and Revisions to the Accounting for Derivatives Instruments and Hedging Activities-Impairment (File Reference No. 2011-50)
- January 28, 2011, AICPA comment letter on the FASB Discussion Paper Effective Dates and Transition Methods
- December 28, 2010 AICPA comment letter on the FASB Exposure Draft - Leases
- November 30, 2010 AICPA comment letter on the FASB Discussion Paper - Preliminary Views on Insurance Contracts (the DP)
- September 30, 2010, FinREC comment letter on the Exposure Draft: Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities.
- August 23, 2010 comment letter on FASB's Proposed Accounting Standards Update, Disclosure of Certain Loss Contingencies
- July 12, 2010 comment letter on FASB/IASB's Exposure Draft, Conceptual Framework for Financial Reporting: The Reporting Entity
- December 7, 2009 comment letter on FASB's Measurement of Financial Instruments
- October 9, 2009 comment letter on FASB's Exposure Draft on Improving Disclosures about Fair Value Measurements
- August 26, 2009 comment letter on FASB's A Practical Expedient for Reporting the Fair Value of Interests in Perpetual Trusts
- FinREC's July 27, 2009 comment letter on the joint FASB/IASB Discussion Paper, Preliminary Views on Revenue Recognition in Contracts with Customers
- July 7, 2009 comment letter on proposed FASB Staff Position (FSP) FAS 157-g, “Estimating the Fair Value of Investments in Investment Companies That Have Calculated Net Asset Value per Share in Accordance with the AICPA Audit and Accounting Guide, Investment Companies”
- April 14, 2009 comment letter on FASB’s Financial Statement Presentation Discussion Paper
- FinREC April 1, 2009 comment letter on the FASB's Proposed Staff Positions (1) FSP FAS 115-a, FAS 124-a, and EITF 99-20-b, Recognition and Presentation of Other-Than-Temporary Impairments, and (2) FSP FAS 157-e, Determining Whether a Market is Not Active and a Transaction is Not Distressed
- FinREC's November 17, 2008 comment letter on FASB's ED on Accounting for Transfers of Financial Assets, an amendment of FASB Statement No. 140
- FinREC’s October 9, 2008 comment letter on the FASB's and IASB’s May 29, 2008 Exposure Draft, The Objective of Financial Reporting and Qualitative Characteristics and Constraints of Decision-Useful Financial Reporting Information. (FinREC asks for NPOs to be scoped in.)
- FinREC’s October 9, 2008 comment letter on the FASB's and IASB’s May 29, 2008 Preliminary Views, Conceptual Framework for Financial Reporting: The Reporting Entity. (FinREC asks for NPOs to be scoped in.)
- May 30, 2008 FinREC comment letter to FASB Preliminary Views Document, Financial Instruments with Characteristics of Equity
- April 15, 2008 PSC comment letter to FASB on FSP, Endowments of Not-for-Profit Organizations: Net Asset Classification of Funds Subject to an Enacted Version of the Uniform Prudent Management of Institutional Funds Act, and Enhanced Disclosures
- January 16, 2008 FinREC comment letter to FASB on FAS 142-f, Determination of the Useful Life of Intangible Assets
