Accounting and Financial Reporting – Positions and Comment Letters

The AICPA, and its committees and task forces, have issued the following comment letters to communicate its views and positions on accounting and financial reporting proposals issued by standard setters, such as FASB, GASB, and the IASB.

Letters to FASB
May 30, 2024 comment letter on the Financial Accounting Foundation’s Review of the Private Company Council
April 8, 2024 FinREC comment letter on FASB’s Proposed Statement of Financial Accounting Concepts, Concepts Statement No. 8, Conceptual Framework for Financial Reporting, Chapter 6: Measurement
Comment Letter dated December 4, 2023 on FASB’s Proposed Accounting Standards Update, “Income Statement—Reporting Comprehensive Income—Expense Disaggregation Disclosures (Subtopic 220-40) Disaggregation of Income Statement Expenses”
Comment Letter dated October 11, 2023 on FASB’s Proposed Accounting Standards Update, “Financial Instruments – Credit Losses (Topic 326)” (“ED”)
Comment Letter on June 5, 2023 FASB’s Proposed Accounting Standards Update, Intangibles—Goodwill and Other— Crypto Assets (Subtopic 350-60)– Accounting for and Disclosure of Crypto Assets
Comment Letter on May 31, 2023 FASB’s Proposed Accounting Standards Update, Income Taxes (Topic 740) Improvements to Income Tax Disclosures
Comment Letter on FASB’s Business Combinations— Joint Venture Formations
December 12, 2022 Comment Letter on FASB’s Proposed Accounting Standards Update, Segment Reporting (Topic 280) – Improvements to Reportable Segment Disclosures
September 21, 2022 FinREC Comment Letter on FASB's Invitation to Comment, Accounting for Government Grants by Business Entities
April 4, 2022 FinREC comment letter on FASB's Proposed Accounting Standards Update (ASU), “Liabilities – Supplier Finance Programs (Subtopic 405-50) – Disclosure of Supplier Finance Program Obligations.”
December 23, 2021 Finrec Comment Letter on FASB's Proposed ASU- Credit Losses - Troubled Debt Restructurings and Vintage Disclosures
September 17, 2021 FinREC's comment letter on FASB’s Invitation to Comment (ITC) Agenda Consultation
July 23, 2021 FinREC comment letter to FASB “Agenda Request - Clarification for Employee Benefit Plan Accounting”
March 22, 2021 FinREC comment letter to FASB on FASB Proposed Accounting Standards Update (ASU), “Business Combinations (Topic 805)–Accounting for Contract Assets and Contract Liabilities from Contracts with Customers.”
December 4, 2020 AICPA FinREC comment letter on the Financial Accounting Standards Board’s July 16, 2020, Exposure Draft—Concepts Statement No. 8, Conceptual Framework for Financial Reporting—Chapter 4: Elements of Financial Statements
August 6, 2020 - FinREC comment letter on the IASB’s December 2019 Exposure Draft: General Presentation and Disclosures (Primary Financial Statements).
March 9, 2020 - FinREC comment letter on Financial Accounting Standards Board’s February 10, 2020, Exposure Draft of a Proposed Accounting Standards Update—Not-for-Profit Entities (Topic 958): Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets.
October 19, 2019 - FinREC comment letter on FASB's July 31, 2019 Exposure Draft: Debt—Debt with Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging—Contracts in Entity’s Own Equity (Subtopic 815-40)
October 3, 2019 comment letter on FASB Invitation to Comment (ITC), “Identifiable Intangible Assets and Subsequent Accounting for Goodwill.”
July 15, 2019 - FinREC comment letter on FASB's May 14, 2019, Exposure Draft, Income Taxes (Topic 740)— Simplifying the Accounting for Income Taxes
June 7, 2019 Financial Accounting Standards Board’s (FASB or Board) March 25, 2019 Exposure Draft, Income Taxes (Topic 740)—Disclosure Framework—Changes to the Disclosure Requirements for Income Taxes.
February 1, 2019 comment letter on FASB's Dec. 2018 Exposure Draft of Proposed changes to Extending the Private Company Accounting Alternatives on Goodwill and Certain Identifiable Intangible Assets to Not-for-Profit Entities. 
August 9, 2018, comment letter on Financial Accounting Standards Board’s June 26, 2018, Exposure Draft of a Proposed Accounting Standards Update—Not-for-Profit Entities (Topic 958): Updating the Definition of Collections
June 19, 2018, Proposed Accounting Standards Update (ASU), Collaborative Arrangements (Topic 808) — Targeted Improvements from the Financial Accounting Standards Board (FASB or Board).
September 27, 2017 comment letter on the Proposed Accounting Standards Update (ASU), Not-for-Profit Entities (Topic 958), Clarifying the Scope and the Accounting Guidance for Contributions Received and Contributions Made
December 14, 2016, comment letter on the Proposed Accounting Standards Update (ASU), Financial Services – Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts
November 30, 2016, comment letter on the Proposed Accounting Standards Update (ASU), Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities
October 20, 2016, comment letter on FASB’s August 4, 2016, Invitation to Comment Agenda Consultation
July 13, 2016, comment letter on the Proposed FASB Accounting Standards Update (ASU), Intangibles — Goodwill and Other (Topic 350) - Simplifying the Accounting for Goodwill Impairment.
February 10, 2016, comment letter on FASB's Exposure Draft, Government Assistance (Topic 832) Disclosures by Business Entities about Government Assistance
February 8, 2016, comment letter on the FASB’s Proposals: 1) Conceptual Framework for Financial Reporting, Chapter 3 - Qualitative Characteristics of Useful Financial Information; and (2) Notes to Financial Statements – Assessing Whether Disclosures are Material.
August 11, 2015, comment letter on the Proposed Accounting Standards Update, Not-for-Profit Entities (Topic 958) and Health Care Entities (Topic 954): Presentation of Financial Statements of Not-for-Profit Entities.
February 23, 2015, comment letter on the Proposed Accounting Standards Update, Financial Services—Investment Companies (Topic 946): Disclosures about Investments in Other Investment Companies.
July 22, 2014, comment letter on the Exposure Draft of a Proposed Statement of Financial Accounting Concepts (SFAC), Conceptual Framework for Financial Reporting—Chapter 8: Notes to Financial Statements.
FASB Comment Letter archive
Letters to GASB
December 21, 2023 comment letter on GASB’s Exposure Draft on Disclosure and Classification of Certain Capital Assets
February 17, 2023 comment letter on GASB's Exposure Draft, Additional Proposal for Implementation Guidance Update—2023
January 20, 2023, comment letter on GASB’s Exposure Draft, Implementation Guidance Update—2023
September 29, 2022 comment letter on GASB’s Exposure Draft, Certain Risk Disclosures
September 14, 2021 comment letter on GASB's Revised Exposure Draft, Communication Methods in General Purpose External Financial Reports That Contain Basic Financial Statements: Notes to Financial Statements
September 14, 2021 comment letter on GASB's Exposure Draft, Omnibus 20XX
August 24, 2021 comment letter on GASB'S Exposure Draft, Accounting Changes and Error Corrections
June 23, 2021 comment letter on GASB’s Exposure Draft, The Annual Comprehensive Report
February 26, 2021 comment letter on GASB's Exposure Drafts, Financial Reporting Model Improvements and Recognition of Elements of Financial Statements
February 26, 2021 comment letter on GASB's Preliminary Views, Revenue and Expense Recognition
June 23, 2020 comment letter on GASB’s Proposed Technical Bulletin, Accounting and Financial Reporting Issues Related to the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of 2020 and Coronavirus Diseases
April 10, 2020 comment letter on GASB’s Exposure Draft, Communication Methods in General Purpose External Financial Reports That Contain Basic Financial Statements: Notes to Financial Statements 
April 10, 2020 comment letter on GASB’s Exposure Draft, Certain Component Unit Criteria, and Accounting and Financial Reporting for Internal Revenue Code Section 457 Deferred Compensation Plans
January 30, 2020 comment letter on GASB's Exposure Draft, Implementation Guidance Update- 2020
September 16, 2019 comment letter on GASB's Exposure Draft, Public-Private and Public-Public Partnerships and Availability Payment Arrangements
September 16, 2019 comment letter on GASB's Exposure Draft, Omnibus 20XX
April 30, 2019 comment letter on GASB's Exposure Draft, Leases Implementation Guide
March 8, 2019 comment letter on GASB's Exposure Draft, Fiduciary Activities Implementation Guide
February 14, 2019 comment letter on GASB's Financial Reporting Model Improvements & Recognition of Elements of Financial Statements
October 31, 2018 comment letter on GASB's Exposure Draft, Conduit Debt Obligations

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