The FVS Section serves as the voice of CPAs who provide forensic and valuation services by promoting and protecting member interests with regulators and other third parties. With the assistance of other groups and volunteers, the FVS Team has actively monitored the issues below. Please email us with any questions, concerns or suggestions.
Issues We're Following
Responding to Non-compliance with Laws and Regulations (“NOCLAR”) (issued March 10, 2017)
The Forensic and Valuation Services (“FVS”) Section presents the following comments and observations regarding the potential impact these changes, if implemented, could have on our FVS members and non-FVS members that provide FVS services. FVS Section leadership believes that NOCLAR should not be applicable to any non-attest service (certainly in its current form), and additional consideration should be given to application to attest work. Read the comment letter.
Fair Value Measurements and the Valuation Profession
In 2011, the Chief Accountant of the U.S. Securities Exchange Commission (SEC) expressed concerns about the broadening application of fair value and fair value-based measures in U.S. GAAP and its impact on the reliability and consistency of valuations being conducted for U.S. publicly traded companies. His concerns were related to the following aspects of the valuation profession:
- Lack of a unified identity of valuation experts
- Multiplicity of valuation credentials
- Lack of analytical consistency and valuation work product
- Lack of consistent qualifications and experience for valuation credentials
- Lack of consistent enforcement and disciplinary mechanisms for valuation experts
In 2013, the SEC Chief Accountant noted that valuation professional organizations (VPOs) had started initial discussions on how to address these concerns, but also noted that no substantial changes or progress had been achieved to date.
In 2014, the American Institute of Certified Public Accountants (AICPA), American Society of Appraisers (ASA), Royal Institution of Chartered Surveyors (RICS) and The Appraisal Foundation (TAF), along with global valuation leaders from several large accounting firms and the International Valuation Standards Council (IVSC) began formal discussions regarding proposed solutions to the expressed concerns of the SEC Chief Accountant. Several meetings have been held and significant progress has been made.
During these initial meetings, the participating VPOs agreed to lead the creation of a new shared level of professionalism focused on a mandatory performance framework, education and quality assurance. Current discussions include the concept of a valuation credential issued by VPOs with agreed upon qualifications and requirements. Going forward, the group intends to focus on fair value measurements related to business valuation and intangible assets as performed for public company financial statements.
Representatives of these VPOs intend to meet with the SEC later this month to discuss potential solutions and obtain feedback regarding efforts currently underway. After this meeting, the participating organizations plan to continue to meet in order to further develop this initiative. A specific plan will be submitted to interested stakeholders for public comment later this calendar year.
To see past updates concerning issues we continue to follow with a list of recent comment letters, reports and articles, visit the Advocacy News Archive page.