Following are transcripts of AICPA testimony and comment letters related to various employee benefit plan accounting, reporting, and audit issues.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Financial Instruments (Topic 825) – Disclosures About Liquidity Risk and Interest Rate Risk
October 8, 2012, The AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee to include comments specific to the impact on employee benefit plans in FinREC’s Comment Letter on this FASB Exposure Draft.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Presentation of Financial Statements (Topic 205) – The Liquidation Basis of Accounting
October 4, 2012, The AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee to include comments specific to the impact on employee benefit plans in FinREC’s Comment Letter on this FASB Exposure Draft.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Technical Corrections
AICPA’s Financial Reporting Executive Committee and Employee Benefit Plans Expert Panel’s Joint Comment Letter (December 19, 2011) on FASB Exposure Draft of a Proposed Accounting Standard Update – Technical Corrections.

AICPA Testimony SAS 70 Reports, Fraud and Privacy Principles
On September 1, 2011, Sue Peirce with Apple Growth Partners in Akron, Ohio and a member of the EBPAQC Executive Committee, submitted written testimony on SAS No. 70 reports and the new SSAE 16 Service Organization Control (SOC) reports.

AICPA Testimony on Fraud in Employee Benefits Plans
On September 1, 2011, James Merklin with Bober Markey Fedorovich & Company in Akron, Ohio and a member of the AICPA EBP Expert Panel, submitted written testimony on fraud in employee benefit plans.

AICPA Testimony on Generally Accepted Privacy Principles (GAPP)
On September 1, 2011, Everett Johnson, Chair of the joint AICPA/CICA Privacy Task Force, submitted a letter on Generally Accepted Privacy Principles (GAPP), and the threats or risks to personally identifiable information (PII) and how entities can use GAPP in creating and maintaining a privacy program to help protect this data.

AICPA Testimony on Employee Benefit Plan Auditing and Financial Reporting Models
On June 29, 2010, Marilee Lau and Michele Weldon testified on behalf of the AICPA before the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding employee benefit plan auditing and financial reporting models.

AICPA Testimony on Stable Value Investments
On September 16, 2009, Michele Weldon testified on behalf of the AICPA before the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding stable value investments in employee benefit plans.

AICPA Testimony on Hard-to-Value Assets
On July 15, 2008, Marilee Lau testified on behalf of the AICPA before the Working Group on Hard-to-Value Assets/Target Date Funds of the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding hard-to-value assets.

AICPA Comment Letter on the Certification of Alternative Investments in Limited Scope Audits
On April 19, 2007, the AICPA sent a letter to Bradford P. Campbell, Acting Assistant Secretary of the Employee Benefits Security Administration, U.S. Department of Labor, regarding the certification of alternative investments in a limited scope audit.

AICPA Testimony on Health and Welfare Plan Audits
On September 22, 2004, Alice Wunderlich testified on behalf of the AICPA before the Working Group on Form 5500 Health and Welfare Plan Audits of the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding health and welfare plan audits.