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 FASBGASB, and the IASB.

Letters to FASB
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