Comment Letters

2019 - Back to Top

• Comments to the FASB on a Proposed Accounting Standards Update – Codification Improvements
  12/20/19 Comments on a proposed accounting standards update with amendments that include items raised for FASB consideration through the Codification’s feedback system that met the scope of the FASB's Codification improvement project.
• Comments to the Office of the Comptroller of the Currency - Proposed Interagency Guidance on Credit Risk Review Systems
  12/9/19 Comments to the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, FDIC and the National Credit Union Administration (NCUA) on their joint proposed guidance for credit risk review systems for regulated institutions.
• Comments to the AICPA on a Proposed Statement on Auditing Standards (SAS)—Auditing Accounting Estimates and Related Disclosures
  11/21/19 Comments to the AICPA on a proposed SAS to enhance auditing standards relating to auditing accounting estimates and is intended to enable auditors to address increasingly complex scenarios that arise from new accounting standards that include estimates and related disclosures, and to enhance the auditor’s focus on factors driving estimation uncertainty and potential management bias.
• Comments to the FASB on a Proposed Accounting Standards Update (Revised)—Debt (Topic 470): Simplifying the Classification of Debt in a Classified Balance Sheet (Current versus Noncurrent)
  10/25/19 Comments on a proposed accounting standards update as part of the FASB’s initiative to reduce complexity in accounting standards (Simplification Initiative); with its objective is to identify, evaluate, and improve areas of GAAP for which cost and complexity can be reduced while maintaining or improving the usefulness of the information provided to financial statement users.
• Comments to the FASB in Response to Invitation to Comment – Identifiable Intangible Assets and Subsequent Accounting for Goodwill
  10/7/19 Comments in response to an invitation to comment on the accounting for goodwill on certain identifiable intangible assets acquired in a business combination and whether the benefits justify the costs for public business entities (PBEs).
• Comments to the FASB on a Proposed Accounting Standards Update – Franchisors—Revenue from Contracts with Customers (Subtopic 952-606): Practical Expedient
  10/7/19 Comments on a proposed accounting standards update proposing optional guidance for a limited time to ease the potential burden in accounting for reference rate reform (i.e., concerns about structural risks of interbank offered rates and the risk of cessation of LIBOR), on financial reporting.
• Comments to the FASB on a Proposed Accounting Standards Update – Debt—Debt with Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging—Contracts in Entity’s Own Equity (Subtopic 815-40): Accounting for Convertible Instruments and Contracts in an Entity’s Own Equity
  10/7/19 Comments on a proposed accounting standards update intended to address issues identified as a result of the complexity associated with applying GAAP for certain financial instruments with characteristics of liabilities and equity.
• Comments to the FASB on a Proposed Accounting Standards Update – Debt—Debt with Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging—Contracts in Entity’s Own Equity (Subtopic 815-40): Accounting for Convertible Instruments and Contracts in an Entity’s Own Equity
  10/7/19 Comments on a proposed accounting standards update intended to address issues identified as a result of the complexity associated with applying GAAP for certain financial instruments with characteristics of liabilities and equity.
• Comments to the Adult Care Facility (ACF) Division of the New York State Department of Health Proposed Revisions on Proposed Revisions to ACF and Related Agency Medicaid Cost Reports
  10/7/19 Comments on proposed revisions to ACF and related agency Medicaid cost reports so that the language for auditor opinions in the reports comply with generally accepted auditing standards in the US.
• Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments—Credit Losses (Topic 326), Derivatives and Hedging (Topic 815), and Leases (Topic 842): Effective Dates
  9/13/19 Comments on a proposed accounting standards update to address implementation challenges encountered by all types of entities when adopting a major Update and to extend and simplify how effective dates are staggered between larger public companies and all other entities.
• Comments to the FASB on a Proposed Accounting Standards Update – Financial Services—Insurance (Topic 944): Effective Date
  9/13/19 Comments on a proposed accounting standards update that would defer the effective date of the amendments in Update 2018-12 for all entities.
• Comments to the AICPA on a Proposed SSARS – Materiality in a Review of Financial Statements, Adverse Conclusions, and Special Purpose Frameworks
  9/13/19 Comments to the AICPA on a proposed Statement on Standards for Accounting and Review Services (SSARS) that contains revisions to certain sections of SSARS 21 (as amended).
• Comments to the AICPA on a Proposed SAS – Audit Evidence
  9/13/19 Comments to the AICPA on a proposed Statement on Auditing Standards (SAS) that would supersede SAS No. 122, Statements on Auditing Standards: Clarification and Recodification, as amended, section 500, Audit Evidence (AU-C section 500).
• Comments to NASBA and AICPA on Exposure Draft of Proposed Changes to CPE Standards
  8/30/19 Comments to NASBA and the AICPA on proposed revisions to the Statement on Standards for Continuing Professional Education (CPE) Programs (Standards). Published jointly by NASBA and the AICPA, the Standards provide a framework for the development, presentation, measurement and reporting of CPE programs.
• Comments to the FASB on a Proposed Accounting Standards Update – Investments—Equity Securities (Topic 321), Investments—Equity Method and Joint Ventures (Topic 323), and Derivatives and Hedging (Topic 815): Clarifying the Interactions between Topic 321, Topic 323, and Topic 815 (a consensus of the Emerging Issues Task Force)
  8/23/19 Comments on a proposed accounting standards update that would clarify the interaction of the accounting for equity securities under Topic 321 and investments under the equity method of accounting in Topic 323 and the accounting for certain forward contracts and purchased options accounted for under Topic 815.
• Comments to the AICPA and NASBA on CPA Evolution: Request for Input: A Joint Project of NASBA and the AICPA
  8/8/19 Comments to the AICPA and NASBA on The vision of CPA Evolution, a joint project of NASBA and the AICPA, which is to transform the CPA profession and its licensure model in recognition of the need for rapidly changing CPA skills and competencies necessitated by constantly escalating technological disruption.
• Comments to the IAASB on their Exposure Drafts for Quality Management at the Firm and Engagement Level, Including Engagement Quality Reviews
  7/31/19 Comments to the IAASB on three interrelated standards that address quality management. Exposure Draft, Proposed International Standard on Quality Management 1, Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements (ED-ISQM 1); Exposure Draft, Proposed International Standard on Quality Management 2, Engagement Quality Reviews (ED-ISQM 2); and Exposure Draft, Proposed International Standard on Auditing 220 (Revised), Quality for an Audit of Financial Statements (ED-220).
• Comments to the FASB on a Proposed Accounting Standards Update – Codification Improvements to Topic 326, Financial Instruments—Credit Losses
  7/19/19 Comments on a proposed accounting standards update containing amendments to clarify or address stakeholders’ specific issues about certain aspects of the amendments in Update 2016-13, Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments.
• Comments to the Internal Revenue Service on Draft Form W-4, Employee’s Withholding Allowance Certificate
  7/1/19 Comments and recommendations to the Internal Revenue Service on the Draft of the 2020 IRS Form W-4, Employee’s Withholding Allowance Certificate.
• Comments to the FASB on a Proposed Accounting Standards Update – Disclosure Improvements: Codification Amendments in Response to the SEC's Disclosure Update and Simplification Initiative
  6/28/19 Comments on a proposed accounting standards update with proposed amendments resulting from FASB's consideration of referred disclosures from the SEC (Release No. 33-10532).
• Comments to the FASB on a Proposed Accounting Standards Update – Income Taxes (Topic 740): Simplifying the Accounting for Income Taxes
  6/28/19 Comments on a proposed accounting standards update with proposed amendments to simplify the accounting for income taxes by removing certain exceptions to the general principles in Topic 740 and to improve consistent application of and simplify GAAP for other areas of Topic 740.
• Comments on NYC Department of Consumer Affairs (DCA) Proposed Amendments of Rules Governing Tax Preparers
  5/8/19 A letter to NYC DCA on proposed signage rules for preparers of tax returns and matters of their applicability to licensed CPAs.
• Comments to the FASB on a Proposed Accounting Standards Update – Business Combinations (Topic 805): Revenue from Contracts with Customers—Recognizing an Assumed Liability (a consensus of the FASB Emerging Issues Task Force)
  4/30/19 Comments on a proposed accounting standards update to address the diversity in views about the circumstances in which an entity should recognize a contract liability from a contract with a customer within the scope of Topic 606 that is acquired in a business combination.

• Comments to the FASB on Invitation to Comment—Measurement and Other Topics Related to Revenue Contracts with Customers under Topic 805
  4/30/19 Comments on a FASB Invitation to Comment soliciting feedback about measurement and other topics related to revenue contracts with customers under Topic 805 that were identified by the Emerging Issues Task Force during consideration of EITF Issue 18-A.
• A Report of the NYSSCPA Estate Planning and Trusts and Estates Administration Committees: Proposed Amendment to Section 954(a)(3) of the New York Tax Law
  3/28/19 An analysis and report of the NYSSCPA Estate Planning and Trusts and Estates Administration Committees on the proposed amendment to Section 954(a)(3) of the New York Tax Law contained in the Governor’s Fiscal Year 2020 Executive Budget released on January 15, 2019.
• Comments to the IAASB on Proposed International Standard on Related Services 4400 (Revised), Agreed-Upon Procedures Engagements
  3/7/19 Comments on an IAASB exposure draft of ISRS 4400 intended to ensure that the IAASB’s standard on AUP engagements remains relevant in the current business environment, and proposes to enhance key concepts including the role of professional judgment, disclosures relating to independence, guidance on terminology, use of an expert and restriction on distribution and use of an AUP report.
• Comments to AICPA PEEC on an Exposure Draft, Proposed Interpretation—Staff Augmentation Arrangements Interpretation (ET sec. 1.295.157)
  2/25/19 Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of a proposed interpretation to provide guidance regarding situations in which a member or a member’s firm provides human resource capital as a service to clients under a staff augmentation arrangement.
• Comments to the FASB on a Proposed Accounting Standards Update – Intangibles—Goodwill and Other (Topic 350), Business Combinations (Topic 805), and Not-for-Profit Entities (Topic 958): Extending the Private Company Accounting Alternatives on Goodwill and Certain Identifiable Intangible Assets to Not-for-Profit Entities
  2/15/19 Comments on a proposed accounting standards update intended to provide provide accounting alternatives that would reduce the cost and complexity associated with the subsequent accounting for goodwill and the measurement of certain identifiable intangible assets acquired without significantly diminishing decision-useful information for users of NFP financial statements.
• Comments to the U.S. Treasury: Investing in Qualified Opportunity Funds (REG-115420-18) – Proposed Regulations Under Code Section 1400Z-2
  1/9/19 Comments to the U.S. Department of the Treasury on proposed regulations that provide guidance under new section 1400Z-2 of the Internal Revenue Code relating to gains that may be deferred as a result of a taxpayer's investment in a qualified opportunity fund.

2018 - Back to Top

• Comments to the FASB on a Proposed Accounting Standards Update – Codification Improvements - Financial Instruments
  12/18/18 Comments on a proposed accounting standards update intended to provide clarification and correction to certain areas identified in previous standards updates regarding financial instruments.
• Letter to the Office of NYS Governor Andrew M. Cuomo Recommending Signing Bill A.10648 / S.8522-A into Law, and Removing the Exemption from CPE for Newly Licensed CPAs
  12/17/18 Letter to the Office of NYS Governor Andrew M. Cuomo recommending the signing of Bill A.10648 / S.8522-A into law. The legislation removes the initial three year exemption from mandatory continuing education for newly licensed CPAs.
• Comments to the IAASB on Proposed International Standard on Auditing 315 (Revised): Identifying and Assessing the Risks of Material Misstatement
  10/31/18 Comments on an IAASB exposure draft of an international auditing standard intended to set out the risk assessment procedures that form the foundation for an audit of financial statements.
• Comments to the AICPA on an Exposure Draft – Proposed Statement on Standards for Attestation Engagements—Revisions to Statement on Standards for Attestation Engagements No. 18, Attestation Standards: Clarification and Recodification
  10/9/18 Comments on proposed revisions to SSAE 18, applicable when a practitioner performs an agreed-upon procedures engagement or reports directly on subject matter. If adopted, this will supersede AT-C section 105, Concepts Common to All Attestation Engagements; AT-C section 205, Examination Engagements; AT-C section 210, Review Engagements; and AT-C section 215, Agreed-Upon Procedures Engagements.
• Comments to the FASB on a Proposed Accounting Standards Update – Leases (Topic 842): Narrow-Scope Improvements for Lessors
  9/10/18 Comments on a proposed accounting standards update intended to aid lessor stakeholders on certain issues that they are experiencing when applying Topic 842.
• Comments to the FASB on a Proposed Accounting Standards Update – Codification Improvements to Topic 326, Financial Instruments-Credit Losses
  9/10/18 Comments on a proposed accounting standards update for improvements related to Update 2016-13 to increase stakeholders’ awareness of the proposed amendments to scope and transition and effective date requirements and to expedite the improvements.
• Comments to the National Institute of Standards and Technology (NIST) – Draft NIST Special Publication 800-163 Revision 1 – Vetting the Security of Mobile Applications
  9/4/18 Comments on a draft special publication updating processes for vetting mobile applications to ensure that mobile apps conform to an organization's security requirements and are reasonably free from vulnerabilities.
• Comments to AICPA PEEC on Exposure Draft, Proposed Interpretation—Disclosing Client Information in Connection With a Quality Review
  8/8/18 Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of a proposed interpretation to clarify the rules surrounding disclosure of client information in connection with a quality review.
• Comments to the FASB on a Proposed Accounting Standards Update – Not-for-Profit Entities (Topic 958): Updating the Definition of Collections
  10/7/19 Comments on proposed revisions to ACF and related agency Medicaid cost reports so that the language for auditor opinions in the reports comply with generally accepted auditing standards in the US.
• Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments—Credit Losses (Topic 326), Derivatives and Hedging (Topic 815), and Leases (Topic 842): Effective Dates
  9/13/19 Comments on a proposed accounting standards update to address implementation challenges encountered by all types of entities when adopting a major Update and to extend and simplify how effective dates are staggered between larger public companies and all other entities.
• Comments to the FASB on a Proposed Accounting Standards Update – Financial Services—Insurance (Topic 944): Effective Date
  9/13/19 Comments on a proposed accounting standards update that would defer the effective date of the amendments in Update 2018-12 for all entities.
• Comments to the AICPA on a Proposed SSARS – Materiality in a Review of Financial Statements, Adverse Conclusions, and Special Purpose Frameworks
  9/13/19 Comments to the AICPA on a proposed Statement on Standards for Accounting and Review Services (SSARS) that contains revisions to certain sections of SSARS 21 (as amended).
• Comments to the AICPA on a Proposed SAS – Audit Evidence
  9/13/19 Comments to the AICPA on a proposed Statement on Auditing Standards (SAS) that would supersede SAS No. 122, Statements on Auditing Standards: Clarification and Recodification, as amended, section 500, Audit Evidence (AU-C section 500).
• Comments to NASBA and AICPA on Exposure Draft of Proposed Changes to CPE Standards
  8/30/19 Comments to NASBA and the AICPA on proposed revisions to the Statement on Standards for Continuing Professional Education (CPE) Programs (Standards). Published jointly by NASBA and the AICPA, the Standards provide a framework for the development, presentation, measurement and reporting of CPE programs.
• Comments to the FASB on a Proposed Accounting Standards Update – Investments—Equity Securities (Topic 321), Investments—Equity Method and Joint Ventures (Topic 323), and Derivatives and Hedging (Topic 815): Clarifying the Interactions between Topic 321, Topic 323, and Topic 815 (a consensus of the Emerging Issues Task Force)
  8/23/19 Comments on a proposed accounting standards update that would clarify the interaction of the accounting for equity securities under Topic 321 and investments under the equity method of accounting in Topic 323 and the accounting for certain forward contracts and purchased options accounted for under Topic 815.
• Comments to the AICPA and NASBA on CPA Evolution: Request for Input: A Joint Project of NASBA and the AICPA
  8/8/19 Comments to the AICPA and NASBA on The vision of CPA Evolution, a joint project of NASBA and the AICPA, which is to transform the CPA profession and its licensure model in recognition of the need for rapidly changing CPA skills and competencies necessitated by constantly escalating technological disruption.
• Comments to the IAASB on their Exposure Drafts for Quality Management at the Firm and Engagement Level, Including Engagement Quality Reviews
  7/31/19 Comments to the IAASB on three interrelated standards that address quality management. Exposure Draft, Proposed International Standard on Quality Management 1, Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements (ED-ISQM 1); Exposure Draft, Proposed International Standard on Quality Management 2, Engagement Quality Reviews (ED-ISQM 2); and Exposure Draft, Proposed International Standard on Auditing 220 (Revised), Quality for an Audit of Financial Statements (ED-220).
• Comments to the FASB on a Proposed Accounting Standards Update – Codification Improvements to Topic 326, Financial Instruments—Credit Losses
  7/19/19 Comments on a proposed accounting standards update containing amendments to clarify or address stakeholders’ specific issues about certain aspects of the amendments in Update 2016-13, Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments.
• Comments to the Internal Revenue Service on Draft Form W-4, Employee’s Withholding Allowance Certificate
  7/1/19 Comments and recommendations to the Internal Revenue Service on the Draft of the 2020 IRS Form W-4, Employee’s Withholding Allowance Certificate.
• Comments to the FASB on a Proposed Accounting Standards Update – Disclosure Improvements: Codification Amendments in Response to the SEC's Disclosure Update and Simplification Initiative
  6/28/19 Comments on a proposed accounting standards update with proposed amendments resulting from FASB's consideration of referred disclosures from the SEC (Release No. 33-10532).
• Comments to the FASB on a Proposed Accounting Standards Update – Income Taxes (Topic 740): Simplifying the Accounting for Income Taxes
  6/28/19 Comments on a proposed accounting standards update with proposed amendments to simplify the accounting for income taxes by removing certain exceptions to the general principles in Topic 740 and to improve consistent application of and simplify GAAP for other areas of Topic 740.
• Comments on NYC Department of Consumer Affairs (DCA) Proposed Amendments of Rules Governing Tax Preparers
  5/8/19 A letter to NYC DCA on proposed signage rules for preparers of tax returns and matters of their applicability to licensed CPAs.
• Comments to the FASB on a Proposed Accounting Standards Update – Business Combinations (Topic 805): Revenue from Contracts with Customers—Recognizing an Assumed Liability (a consensus of the FASB Emerging Issues Task Force)
  4/30/19 Comments on a proposed accounting standards update to address the diversity in views about the circumstances in which an entity should recognize a contract liability from a contract with a customer within the scope of Topic 606 that is acquired in a business combination.

• Comments to the FASB on Invitation to Comment—Measurement and Other Topics Related to Revenue Contracts with Customers under Topic 805
  4/30/19 Comments on a FASB Invitation to Comment soliciting feedback about measurement and other topics related to revenue contracts with customers under Topic 805 that were identified by the Emerging Issues Task Force during consideration of EITF Issue 18-A.
• A Report of the NYSSCPA Estate Planning and Trusts and Estates Administration Committees: Proposed Amendment to Section 954(a)(3) of the New York Tax Law
  3/28/19 An analysis and report of the NYSSCPA Estate Planning and Trusts and Estates Administration Committees on the proposed amendment to Section 954(a)(3) of the New York Tax Law contained in the Governor’s Fiscal Year 2020 Executive Budget released on January 15, 2019.
• Comments to the IAASB on Proposed International Standard on Related Services 4400 (Revised), Agreed-Upon Procedures Engagements
  3/7/19 Comments on an IAASB exposure draft of ISRS 4400 intended to ensure that the IAASB’s standard on AUP engagements remains relevant in the current business environment, and proposes to enhance key concepts including the role of professional judgment, disclosures relating to independence, guidance on terminology, use of an expert and restriction on distribution and use of an AUP report.
• Comments to AICPA PEEC on an Exposure Draft, Proposed Interpretation—Staff Augmentation Arrangements Interpretation (ET sec. 1.295.157)
  2/25/19 Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of a proposed interpretation to provide guidance regarding situations in which a member or a member’s firm provides human resource capital as a service to clients under a staff augmentation arrangement.
• Comments to the FASB on a Proposed Accounting Standards Update – Intangibles—Goodwill and Other (Topic 350), Business Combinations (Topic 805), and Not-for-Profit Entities (Topic 958): Extending the Private Company Accounting Alternatives on Goodwill and Certain Identifiable Intangible Assets to Not-for-Profit Entities
  2/15/19 Comments on a proposed accounting standards update intended to provide provide accounting alternatives that would reduce the cost and complexity associated with the subsequent accounting for goodwill and the measurement of certain identifiable intangible assets acquired without significantly diminishing decision-useful information for users of NFP financial statements.
• Comments to the U.S. Treasury: Investing in Qualified Opportunity Funds (REG-115420-18) – Proposed Regulations Under Code Section 1400Z-2
  1/9/19 Comments to the U.S. Department of the Treasury on proposed regulations that provide guidance under new section 1400Z-2 of the Internal Revenue Code relating to gains that may be deferred as a result of a taxpayer's investment in a qualified opportunity fund.

2017 - Back to Top

• Comments to Jennifer Winters, Executive Secretary of the the New York State Board for Public Accountancy, on proposed changes regarding the ethics continuing professional education (CPE) requirement for Certified Public Accountants (CPAs)
  12/18/17 Comments on the changes that the New York State Board for Public Accountancy is proposing, regarding the ethics continuing professional education (CPE) requirement for Certified Public Accountants (CPAs), including the proposed 6-credit-hour requirement over the triennial period and the proposed annual 2-credit-hour requirement.
• NY CPAs Call Senate Tax Reform Bill 'Fiscally Irresponsible,' a 'Disaster' for New York's Economy
  12/7/17 NYSSCPA President Harold L. Deiters III, NYSSCPA Tax Division Oversight Chair Edward Arcara and NYSSCPA New York, Multistate and Local Taxation Committee Chair Philip London issue a letter to the New York Sens. Schumer and Gillibrand expressing the NYSSCPA's opposition to certain provisions in HR1, the Tax Cuts and Jobs Act that the NYSSCPA believes will be harmful to New York's economy if enacted.
• Comments to the FASB on a Proposed Accounting Standards Update – Consolidation (Topic 812)—Reorganization
  12/4/17 Comments on a proposed accounting standards update that would reorganize and clarify certain items within the consolidation guidance currently in Topic 810.
• Comments to the IESBA on an Exposure Draft: Proposed Revisions to the Code Pertaining to the Offering and Accepting of Inducements
  12/4/17 Comments to the International Ethics Standards Board for Accountants (IESBA) on an exposure draft of proposed revisions to the Code related to offering and accepting of inducements by professional accountants in business and public practice; and related conforming amendments to the independence provisions relating to gifts and hospitality.
• Comments to the FASB on a Proposed Accounting Standards Update – Codification Improvements
  12/1/17 Comments on a proposed accounting standards update to address suggestions received from stakeholders on the Codification and to make other incremental improvements to GAAP.
• NY CPAs Call House Tax Reform Bill 'Fiscally Irresponsible,' a 'Disaster' for New York's Economy
  11/27/17 NYSSCPA President Harold L. Deiters III, NYSSCPA Tax Division Oversight Chair Edward Arcara and NYSSCPA New York, Multistate and Local Taxation Committee Chair Philip London issue a letter to the the New York House Delegation expressing the  NYSSCPA's opposition to certain provisions in HR1, the Tax Cuts and Jobs Act that the NYSSCPA believes will be harmful to New York's economy if enacted.
• Comments to the PCAOB on Release No. 2017-005 - Proposed Auditing Standard—Supplemental Request for Comment – Proposed Amendments Relating to the Supervision of Audits Involving Other Auditors and Proposed Auditing Standard – Dividing Responsibility for the Audit with Another Accounting Firm (Docket Matter No. 042)
  11/13/17 Comments to the PCAOB on its supplemental request for comment on its April 12, 2016, proposed amendments and proposed standard regarding audits that involve accounting firms and individual accountants outside the accounting firm that issues the audit report. This supplemental request for comment seeks commenters' views on certain revisions to the proposed amendments and proposed standard that the Board is considering for adoption.
• Comments to the FASB on Two Proposed Accounting Standards Updates – Technical Corrections and Improvements to ASU 2016-01, Financial Instruments and to ASU 2016-02, Leases
  11/13/17 Comments on Two Proposed Accounting Standards Updates—Technical Corrections and Improvements to Recently Issued Standards: I. Accounting Standards Update No. 2016-01, Financial Instruments—Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities and II. Accounting Standards Update No. 2016-02, Leases (Topic 842).
• Comments to the New York City Department of Housing Preservation and Development - Proposed Template for Independent Accountant’s Report on Applying Agreed-Upon Procedures for Purposes of the J-51 Property Tax Exemption and Abatement Application
  10/31/17 - NYSSCPA's offer to NYC HPD of a proposed template for the independent accountant's report on applying agreed-upon procedures for purpose's of the City's J-51 Property Tax Exemption and Abatement Application that would be acceptable for use by both practitioners and NYC HPD.
• Comments to the FASB on a Proposed Accounting Standards Update – Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made
  10/30/17 Comments on a proposed accounting standards update to clarify and improve the scope and the accounting guidance for contributions received and contributions made. To assist entities in evaluating whether transactions should be accounted for as contributions (nonreciprocal transactions) within the scope of Topic 958 or as exchange (reciprocal) transactions subject to other guidance; and in distinguishing between conditional contributions and unconditional contributions.
• Comments to the FASB on a Proposed Accounting Standards Update – Leases (Topic 842): Land Easement Practical Expedient for Transition to Topic 842
  10/19/17 Comments on a proposed accounting standards update that would clarify that land easements should be evaluated under Topic 842, and would address cost and complexity concerns in complying with the transition requirements in Topic 842 for land easements not previously assessed under Topic 840 by providing an optional transition expedient.
• Comments to the New York State Department of Taxation and Finance with regard to the driver license requirement that is to become mandatory for the 2017 filing season
  10/10/17 The NYSSCPA warns the NYSDTF of heightened cyberattack risk for accounting firms if the Department's driver license requirement continues. The Society urges the NYSDTF to continue to allow voluntary compliance with the requirement for tax practitioners to include taxpayer driver license information when e-filing client returns for the 2017 tax year until the state can implement a more secure taxpayer identity-authentication solution.
• Comments to the AICPA on an Exposure Draft – Proposed Update to Section 14 of the Uniform Accountancy Act (UAA) As It Relates to the Use of Management Accounting Designations by Non-CPAs
  10/2/17 Comments on a joint AICPA NASBA exposure draft proposing changes to Section 14 of the UAA. The proposed changes would allow non-CPAs to assume or use management accounting designations with certain caveats or restrictions.
• Comments to the IASB on an IFRS Discussion Paper – Disclosure Initiative - Principles of Disclosure
  9/29/17 -Comments on an IASB discussion paper that suggests principles to make disclosures in financial statements more effective.
• Comments to AICPA PEEC on Exposure Draft, Proposed Interpretation – Long Association of Senior Personnel With an Attest Client
  9/15/17 -Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of a proposed interpretation, the purpose of which is to provide clarity on the new ethics standard, Long Association of Personnel with an Audit Client, of the International Ethics Standards Board for Accountants (IESBA) to make it relevant to AICPA members in the United States.
• Comments to the FASB on a Proposed Accounting Standards Update – Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for Variable Interest Entities
  8/31/17 -Comments on a proposed accounting standards update in response to stakeholders’ observations that Topic 810, could be improved in: applying the VIE guidance to private companies under common control; considering indirect interests held through related parties under common control for determining whether fees paid to decision makers and service providers are variable interests; applying certain requirements when power is shared among related parties or when related parties under common control have a controlling financial interest in a VIE but none of the parties individually have a controlling financial interest.
• Comments to the AICPA ASB on an Exposure Draft: Proposed Statement on Auditing Standards (SAS)—Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA
  8/18/17 -Comments to the AICPA Auditing Standards Board (ASB) on an exposure draft issued in response to concerns over the quality of employee benefit plan (EBP) audits, with the goals of providing an audit report that clarifies audit procedures and the responsibilities of auditors and management, and improving quality and transparency.
• Comments to the FASB on a Proposed Accounting Standards Update – Technical Corrections and Improvements to Topic 942, Financial Services—Depository and Lending: Elimination of Certain Guidance for Bad Debt Reserves of Savings and Loans
  8/14/17 -Comments on a proposed accounting standards update that would supersede outdated deferred tax guidance on bad debt reserves of savings and loans that arose after December 31, 1987, and guidance related to the Comptroller of the Currency’s Banking Circular 202, Accounting for Net Deferred Tax Charges.
• Comments to the IASB on an Exposure Draft – Improvements to IFRS 8 Operating Segments (Proposed amendments to IFRS 8 and IAS 34)
  7/26/17 -Comments on an IASB exposure draft of proposed clarifications and amendments on five issues resulting from IASB's post implementation review of IFRS 8, Operating Segments.
• Comments to the IESBA on an Exposure Draft: Proposed Application Material Relating to Professional Skepticism and Professional Judgment
  7/14/17 -Comments to the International Ethics Standards Board for Accountants (IESBA) on an exposure draft of proposed application material relating to (a) Professional Skepticism – Linkage with the Fundamental Principles; and (b) Professional Judgment – Emphasis on Understanding Facts and Circumstances.
• Comments to NASBA on an Exposure Draft: Draft Model Rules for Continuing Professional Education (CPE)
  6/23/17 -Comments to the National Association of State Boards of Accountancy (NASBA) on their exposure draft of revised model rules for CPE that are directed to licensees and are provided as a set of rules prescribing baseline standards for use by Boards of Accountancy in state rules and laws.
• Comments to the FASB on a Proposed Accounting Standards Update – Compensation – Stock Compensation (Topic 718): Improvements to Nonemployee Share-Based Payment Accounting
  5/30/17 -Comments on a proposed accounting standards update, the objective of which is to is to simplify and reduce related costs for the accounting for nonemployee share-based payment awards by conforming the accounting to that used for employee share-based payment awards, while maintaining or improving the usefulness of the information provided to the users of the financial statements.
• Comments to AICPA on Exposure Draft, AICPA Professional Ethics Division – Proposed Interpretations, Responding to Non-Compliance with Laws and Regulations, March 10, 2017
  5/8/17 -Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of two new interpretations, each entitled “Responding to Non-Compliance with Laws and Regulations” (ET sec. 1.170.010 and 2.170.010) under the “Integrity and Objectivity Rule” (ET sec. 1.100.001 and 2.100.001), applicable to members in public practice and in business, respectively.
• Comments to the FASB on a Proposed Accounting Standards Update – Debt (Topic 470): Simplifying the Classification of Debt in a Classified Balance Sheet (Current versus Noncurrent)
  5/1/17 -Comments on a proposed accounting standards update that would replace the current, fact-specific guidance on determining whether debt should be classified as current or noncurrent in a classified balance sheet with an overarching, cohesive principle.
• Comments to AICPA on Exposure Draft, AICPA Professional Ethics Division – Omnibus Proposal, Proposed Revised and New Interpretations Applicable to Members in Business, January 9, 2017
  4/12/17 -Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft containing revisions to the “Knowing Misrepresentations in the Preparation of Financial Statements or Records” interpretation (ET sec 2.130.010) 1 under the “Integrity and Objectivity Rule” (ET sec. 2.100.001), applicable to members in business.
• Comments to the National Institute of Standards and Technology - Proposed Cybersecuity Framework Updates
  3/30/17 -Comments on a proposed draft update to the Framework for Improving Critical Infrastructure Cybersecurity, providing new details on managing cyber supply chain risks, clarifying key terms, and introducing measurement methods.
• Comments to the FASB on a Proposed Accounting Standards Update – Inventory (Topic 330): Disclosure Framework—Changes to the Disclosure Requirements for Inventory
  3/7/17 -Comments on a proposed accounting standards update that is part of the FASB's disclosure framework project to improve the effectiveness of disclosures in the notes to financial statements, and specifically, would modify the disclosure requirements for inventory.
• Comments to the FASB on a Proposed Accounting Standards Update – Distinguishing Liabilities from Equity (Topic 480): I. Accounting for Certain Financial Instruments with Down Round Features and II. Replacement of the Indefinite Deferral for Mandatorily Redeemable Financial Instruments of Certain Nonpublic Entities and Certain Mandatorily Redeemable Noncontrolling Interests with a Scope Exception
  1/26/17 -Comments on a proposed accounting standards update, the objective of which is to address issues identified as a result of the complexity associated with applying generally accepted accounting principles (GAAP) for certain financial instruments with characteristics of liabilities and equity.

2013 - Back to Top

• Comments to the FASB on a Proposed Accounting Standards Update – Compensation—Stock Compensation (Topic 718): Accounting for Share-Based Payments When the Terms of an Award Provide That a Performance Target Could Be Achieved after the Requisite Service Period (a consensus of the FASB Emerging Issues Task Force)
  12/19/13 - Comments on a proposed accounting standards update with proposed amendments that are intended to resolve the diverse accounting treatment of share-based payment awards that require a specific performance target to be achieved for employees to benefit.

• Comments to the FASB on a Proposed Accounting Standards Update – Derivatives and Hedging (Topic 815): Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share Is More Akin to Debt or to Equity (a consensus of the FASB Emerging Issues Task Force)
  12/19/13 - Comments on a proposed accounting standards update, the objective of which is to eliminate the use of different methods in practice and thereby reduce existing diversity surrounding the accounting for hybrid financial instruments issued in the form of a share under U.S. GAAP.

• Comments to the FASB on a Proposed Accounting Standards Update – Development Stage Entities (Topic 915): Elimination of Certain Financial Reporting Requirements
  12/19/13 - Comments on a proposed accounting standards update, the objective of which is to improve financial reporting by reducing the cost and complexity associated with the incremental reporting requirements for a development stage entity.

• Comments to Senator Charles E. Schumer on the Cash Method of Accounting for Businesses
  12/18/13 - Comments on limitation on the use of the cash method of accounting for businesses as proposed by Chairman Baucus in his Cost Recovery and Accounting Discussion Draft (November 21, 2013).

• Comments to the PCAOB on Release No. 2013-005 – Proposed Auditing Standards on the Auditor's Report and the Auditor's Responsibilities Regarding Other Information and Related Amendments
  12/10/13 - Comments to the Public Company Accounting Oversight Board on Release No. 2013-005, Proposed Auditing Standards – The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion; The Auditor's Responsibilities Regarding Other Information in Certain Documents Containing Audited Financial Statements and the Related Auditor's Report; and Related Amendments to PCAOB Standards.

• Comments to the IAASB on Proposed International Standard on Auditing - Reporting on Audited Financial Statements: Proposed New and Revised International Standards on Auditing (ISAs)
  11/19/13 - Comments on an exposure draft on expansion of the auditor's report and that includes proposed new ISA 701, Communicating Key Audit Matters in the Independent Auditor’s Report, and a number of proposed revised ISAs, including revisions to ISA 700, Forming an Opinion and Reporting on Financial Statements.

• Comments to the AICPA on Exposure Draft— Proposed Definition of Those Charged With Governance, AICPA Professional Ethics Division, September 10, 2013
  11/5/13 - Comments are being provided to AICPA on the proposed new definition of those charged with governance (paragraph .33 of ET section 92, Definitions [AICPA, Professional Standards]) because the AICPA Code of Professional Conduct refers to those charged with governance in a number of its provisions.

• Letter to NYSDTF -Tax Return Preparer Regulations
  11/1/13 - Proposal of amendments to the Procedural Regulations and Personal Income Tax Regulations to implement certain of the recommendations of the Task Force on Regulation of Tax Return Preparers. 20 NYCRR section 158.12 and Part 2600.

• Comments to the FASB on a Proposed Accounting Standards Update – Consolidation (Topic 810): Applying Variable Interest Entity Guidance to Common Control Leasing Arrangements, a proposal of the Private Company Council
  10/9/13 - Comments on a proposed accounting standards update with proposed amendments that would permit a private company to elect not to apply variable interest entity (VIE) guidance for assessing whether it should consolidate a lessor entity under specified conditions.

• Comments to AICPA on Trust Services Principles and Criteria Exposure Draft
  9/26/13 - The Trust Services Principles and Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy presents criteria established by the Assurance Services Executive Committee (ASEC) of the AICPA for use by practitioners when providing attestation or consulting services to evaluate controls.

• Comments to the FASB on a Proposed Accounting Standards Update – Presentation of Financial Statements (Topic 205): Disclosure of Uncertainties about an Entity’s Going Concern Presumption
  9/23/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance in U.S. GAAP about management’s responsibilities in evaluating an entity’s going concern uncertainties, and about the timing and content of related footnote disclosures.

• Comments to the FASB on a Proposed Accounting Standards Update – Definition of a Public Business Entity: An Amendment to the Master Glossary
  9/16/13 - Comments on a proposed accounting standards update, the primary purposes of which are to amend the Master Glossary of the FASB Accounting Standards Codification® to include one definition of public business entity for use in U.S. GAAP and identify the types of business entities that would be excluded from the scope of the guide.

• Comments to the FASB on a Proposed Accounting Standards Update – Receivables—Troubled Debt Restructurings by Creditors (Subtopic 310-40): Reclassification of Collateralized Mortgage Loans upon a Troubled Debt Restructuring (a consensus of the FASB Emerging Issues Task Force)
  9/16/13 - Comments on a proposed accounting standards update the objective of which is to clarify when an in substance repossession or foreclosure occurs such that all or a portion of the loan should be derecognized and the real estate property recognized.

• Comments to the FASB on a Proposed Accounting Standards Update (Revised) – Leases (Topic 842): a revision of the 2010 proposed FASB Accounting Standards Update, Leases (Topic 840)
  9/11/13 - Comments on a proposed accounting standards update that proposes changes to both lessee and lessor accounting and would supersede IAS 17, Leases (and related Interpretations), in International Financial Reporting Standards (IFRS) and the requirements in Topic 840, Leases (and related Subtopics) of the FASB accounting standards codification.

• Comments to the FASB on a Proposed Accounting Standards Update – Business Combinations (Topic 805): Accounting for Identifiable Intangible Assets in a Business Combination (a proposal of the Private Company Council)
  8/21/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance about an accounting alternative for the recognition, measurement, and disclosure of identifiable intangible assets acquired in a business combination.

• Comments to the FASB on a Proposed Accounting Standards Update – Intangibles—Goodwill and Other (Topic 350): Accounting for Goodwill (a proposal of the Private Company Council)
  8/21/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance about an accounting alternative for the subsequent measurement of goodwill.

• Comments to the FASB on a Proposed Accounting Standards Update – Derivatives and Hedging (Topic 815): Accounting for Certain Receive-Variable, Pay-Fixed Interest Rate Swaps (a proposal of the Private Company Council)
  8/21/13 - Comments on a proposed accounting standards update with amendments that would provide two simpler approaches, the combined instruments approach and the simplified hedge accounting approach, to account for swaps that are entered into for the purposes of economically converting variable-rate borrowing to fixed-rate borrowing.

• Comments to the AICPA on Exposure Draft—AICPA Professional Ethics Division, Proposed Revised AICPA Code of Professional Conduct, April 15, 2013
  8/13/13 - Comments regarding a revised AICPA Code of Professional Conduct (AICPA Code) for possible adoption by the AICPA Professional Ethics Executive Committee (PEEC). The PEEC is proposing to restructure and codify the AICPA Code so that members and other users can apply the rules and reach correct conclusions more easily and intuitively.

• Comments to the FASB on a Proposed Accounting Standards Update – Presentation of Financial Statements (Topic 205): Reporting Discontinued Operations
  8/1/13 - Comments on a proposed accounting standards update that would address reporting issues under Subtopic 205-20 by changing the criteria for reporting discontinued operations and enhancing convergence of the FASB’s and the IASB’s reporting requirements for discontinued operations.

• Comments to the PCAOB on Release No. 2013-004 – Proposed Auditing Standard—Related Parties; Proposed Amendments to Certain PCAOB Auditing Standards Regarding Significant Unusual Transactions; and Other Proposed Amendments to PCAOB Auditing Standards
  7/2/13 - Comments to the Public Company Accounting Oversight Board on Release 2012-004, a reproposal of a new auditing standard, Related Parties; amendments to certain PCAOB auditing standards regarding significant unusual transactions; and other amendments to PCAOB auditing standards. The reproposed standard would supersede the Board's existing auditing standard on related parties, AU sec. 334, Related Parties.

• Comments to the FASB on Invitation to Comment – Private Company Decision-Making Framework: A Guide for Evaluating Financial Accounting and Reporting for Private Companies
  6/21/13 - This FASB Invitation to Comment was issued to solicit comments on a proposed guide for use by the FASB and the Private Company Council (PCC) in considering alternatives for private companies within U.S. generally accepted accounting principles (GAAP).

• Letter of Support for H.R. 1564, the Audit Integrity and Job Protection Act
  6/18/13 - The NYSSCPA sent a letter to certain members of New York's congressional delegation urging support for the bill which would, among other things, prevent the PCAOB from requiring mandatory audit firm rotation.

• Proposed Accounting Standards Update – Financial Instruments—Credit Losses (Subtopic 825-15): File Reference No. 2012-260
  5/31/13 - The main objective in developing this proposal was to provide financial statement users with more decision-useful information about the expected credit losses on financial assets and other commitments to extend credit held by a reporting entity at each reporting date. These proposed amendments also would reduce complexity by replacing the numerous existing impairment models in current U.S. GAAP with a consistent measurement approach.

• Proposed Accounting Standards Update – Fair Value Measurement (Topic 820): Deferral of the Effective Date of Certain Disclosures for Nonpublic Employee Benefit Plans in Update No. 2011-04
  5/29/13 - Stakeholders have raised concerns that certain disclosure requirements in paragraph 820-10-50-2 of the FASB Accounting Standards Codification®, which was effective for nonpublic entities for annual periods beginning after December 15, 2011, would potentially provide proprietary information about nonpublic entities through the dissemination of their employee benefit plans’ financial statements on the regulator’s Web site. The amendments in this proposed Update would address those concerns by permitting an indefinite deferral of certain quantitative disclosure requirements in paragraph 820-10-50-2(bbb) for investments held by a nonpublic employee benefit plan in its plan sponsor’s own nonpublic entity equity securities.

• Proposed Framework for Reorganization of PCAOB Auditing Standards and Related Amendments to PCAOB Auditing Standards and Rules PCAOB Release No. 2013-002, March 26, 2013, PCAOB Rulemaking Docket Matter No. 40
  5/28/13 - The Public Company Accounting Oversight Board ("PCAOB" or "Board") is proposing a framework for reorganizing the existing interim and PCAOB issued auditing standards into a topical structure with a single integrated numbering system. In addition, the PCAOB is proposing certain conforming amendments to Rule 3101, Certain Terms Used in Auditing and Related Professional Practice Standards, and Rule 3200T, Interim Auditing Standards. The Board also is proposing certain related amendments to the PCAOB auditing standards and proposing to rescind certain interim auditing standards that the Board believes are no longer necessary under the proposed reorganization.

• Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments—Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities
  5/14/13 - Comments on a proposed accounting standards update, the objective of which is is to provide financial statement users with more decision-useful information about an entity’s involvement in financial instruments, while reducing the complexity in accounting for those instruments.

• Comments to the FASB on a Proposed Accounting Standards Update – Derivatives and Hedging (Topic 815): Inclusion of the Fed Funds Effective Swap Rate (or Overnight Index Swap Rate) as a Benchmark Interest Rate for Hedge Accounting Purposes (a consensus of the FASB Emerging Issues Task Force) EITF-13A
  4/22/13 - Comments on a proposed accounting standards update, the objective of which is to address whether the Fed Funds Effective Swap Rate (OIS) should be included as a U.S. benchmark interest rate for hedge accounting purposes, in addition to UST and LIBOR.

• Comments to the FASB on a Proposed Accounting Standards Update – Income Taxes (Topic 740): Presentation of an Unrecognized Tax Benefit When a Net Operating Loss Carryforward or Tax Credit Carryforward Exists (a consensus of the FASB Emerging Issues Task Force) EITF - 13C
  4/22/13 - Comments on a proposed accounting standards update, the objective of which is to eliminate the diversity in practice in the presentation of unrecognized tax benefits.

• Comments to the FASB on a Proposed Accounting Standards Update – Transfers and Servicing (Topic 860): Effective Control for Transfers with Forward Agreements to Repurchase Assets and Accounting for Repurchase Financings
  3/19/13 - Comments on a proposed accounting standards update, the objective of which is to improve the existing accounting and disclosure guidance on repurchase agreements and other transactions involving a transfer and a forward agreement to repurchase the transferred assets at a fixed price from the transferee.

• Comments to IAASB on a Proposed International Standard on Auditing (ISA) 720 (Revised), The Auditor’s Responsibilities Relating to Other Information in Documents Containing or Accompanying Audited Financial Statements and the Auditor’s Report Thereon
  3/18/13 - NYSSCPA response to a request for comments by the International Auditing and Assurance Standards Board (IAASB) on proposed ISA 720 (Revised), The Auditor’s Responsibilities Relating to Other Information in Documents Containing or Accompanying Audited Financial Statements and the Auditor’s Report Thereon. The proposals extend the scope of the extant standard and the auditor’s responsibilities and include suggested auditor reporting responsibilities.

• An official letter in opposition sent to New York State Senate Majority Leaders Dean Skelos and Jeffrey Klein and Assembly Speaker Sheldon Silver regarding the education portion of the New York State budget.
  3/14/13 - A formal letter in opposition to legislative leaders regarding amendments added to the 2013 New York State budget bills that removed the requirements for annual internal audits.

• Comments to the IRS on Proposed Regulations under Section 1.1411 Relating to the Net Investment Income Tax
  2/27/13 - Comments on proposed regulations (REG-130507-11) providing guidance for the net investment tax imposed under section 1411. Section 1411 was added by the Health Care and Education Reconciliation Act of 2010, effective for tax years beginning after December 31, 2012, and imposes a 3.8% tax on “net investment income” of higher income individuals and certain estates and trusts to fund the Act.

• Comments to the AICPA on Exposure Draft—Exposure Draft, Proposed Revised Interpretation, AICPA Professional Ethics Division, Subordination of Judgment by a Member, issued November 16, 2012)
  1/14/13 - The Professional Ethics Executive Committee (PEEC) is exposing for comment a proposed revision to Interpretation No. 102-4, “Subordination of Judgment by a Member” under Rule 102, Integrity and Objectivity (AICPA, Professional Standards, ET sec. 102 par.05), of the AICPA Code of Professional Conduct (AICPA Code). PEEC believes that a member should not be precluded from resigning from an organization at any time. The interpretation provides that safeguards should be applied to situations involving a difference of opinion with a supervisor so that a member does not subordinate his or her judgment.

• Comments on AICPA Proposed Statements on Standards for Accounting and Review Services (SSARSS) Review of Financial Statements, Review of Financial Statements—Special Considerations
  1/14/13 - Comment to the AICPA on its Exposure Draft of a Proposed Statement on Standards for Accounting and Review Services – the Exposure Draft represents the redrafting of the paragraphs of SSARS No. 19 to apply the Accounting and Review Services Committee’s (ARSC’s) clarity drafting conventions and to include changes from existing standards in the following sections in the codified SSARSs: AR section 90, Review of Financial Statements (Revised) and AR section 95, Review of Financial Statements—Special Considerations. ARSC is seeking comments specifically on changes resulting from applying the clarity drafting conventions and their effect on the content of the proposed SSARSs.

2012 - Back to Top

• Comments to the Tax Commission of the City of New York - Proposed Independent Auditor's Report for Form TC309 Accountant’s Certification
  12/18/12 - NYSSCPA proposed independent auditor’s report for purposes of NYC Form TC309, Accountant's Certification, to conform with the Clarity Auditing Standards issued by the AICPA effective for audits of entities with a fiscal year ending on or after December 15, 2012.

• Comments to the FASB on a Discussion Paper – Invitation to Comment, Disclosure Framework
  12/17/12 - Response to an invitation to comment on FASB Discussion Paper – Disclosure Framework. The objective and primary focus of the FASB project is to improve the effectiveness of disclosures in notes to financial statements by clearly communicating the information that is most important to users of each entity’s financial statements.

• Comments to the AICPA on Exposure Draft—Omnibus Proposal, AICPA Professional Ethics Division, Interpretations and Definitions (September 19, 2012)
  12/3/12 - Comments on the Professional Ethics Executive Committee (PEEC) September 19, 2012 Omnibus Exposure Draft - Interpretation and Definitions. Proposed are revisions to the definitions of practice of public accounting and professional services as well as deletion of the definition holding out from the AICPA’s Code of Professional Conduct.

• Comments to ISACA on ITAF™ IS Audit and Assurance Standards Exposure Draft
  12/3/12 - Comments to ISACA (Information Systems Audit and Control Association) on an exposure draft of proposed standards for an information technology assurance framework.

• Comments to the FASB on a Discussion Paper – Private Company Decision-Making Framework
  11/8/12 - Response to an invitation to comment (ITC) on FASB Discussion Paper–Private Company Decision-Making Framework, A Framework for Evaluating Financial Accounting and Reporting Guidance for Private Companies. The purpose of the ITC is to gather input from stakeholders about the appropriateness, completeness, and cost effectiveness of the draft private company (nonpublic business entity) decision-making framework. 

• Letter to New York State Board for Public Accountancy Executive Secretary Jennifer Winters, requesting an extension of the CPE filing year as a result of Hurricane Sandy
  11/7/12 - Letter requesting an extension of the CPE reporting year by four weeks in light of the devastation wrought by Hurricane Sandy, and noting that the state took similar action after Hurricane Irene. 

• Comments to the FASB on a Proposed Accounting Standards Update – Comprehensive Income (Topic 220): Presentation of Items Reclassified Out of Accumulated Other Comprehensive Income
  10/19/12 - Comments on a proposed accounting standards update, the objective of which is to improve the presentation of reclassifications out of accumulated other comprehensive income by disclosing their effect on the respective line items in net income if the item being reclassified is required under U.S. GAAP to be reclassified in its entirety to net income.

• Comments on the Second Exposure Draft of Proposed Changes for the 2014-15 Edition of the Uniform Standards of Professional Appraisal Practice
  10/18/12 - The Business Valuation Committee of the New York State Society of Certified Public Accountants (NYSSBV) has reviewed the Second Exposure Draft of Proposed Changes for the 2014-15 Edition of the Uniform Standards of Professional Appraisal Practice (the “Exposure Draft”) and has summarized its comments.

• Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments (Topic 825) Disclosures About Liquidity Risk and Interest Rate Risk
  10/16/12 - Comments on a proposed accounting standards update, the objective of which is to provide users of financial statements with more decision-useful information about entity-level exposures to liquidity risk and interest rate risk.

• NYSSCPA Response to IAASB Invitation to Comment: Improving the Auditor’s Report
  10/2/12 - NYSSCPA response to the International Auditing and Assurance Standards Board (IAASB) Invitation to Comment: Improving the Auditor’s Report (ITC). The ITC sets out the IAASB’s indicative direction proposed for the future of the auditor’s report.

• NYSSCPA Proposal to Reduce Economic Hardships of Early Withdrawals from Individual Taxpayer Retirement Plans
  9/26/12 - NYSSCPA President Gail M. Kinsella sent a letter to the New York State members of the U.S. Senate Finance Committee      (Senator Charles Schumer D-NY) and the U. S. House Ways and Means Committee (Congressmen Joseph Crowley D-NY,  Charles B. Rangel D-NY, Tom Reed R-NY) proposing targeted, short-term exceptions to the 10% additional tax levied on early withdrawals from individual retirement plans to alleviate economic hardships faced by taxpayers as a result of the economic crisis. (The letter linked here is to Senator Schumer).

• Comments to the FASB on a Proposed Accounting Standards Update – Presentation of Financial Statements (Topic 205) The Liquidation Basis of Accounting
  9/26/12 - Comments on a proposed accounting standards update, the objective of which is to clarify when an entity should apply the liquidation basis of accounting and to provide principles for the measurement of assets and liabilities under the liquidation basis as well as any required disclosures.
  
• Comments to the FASB on a Proposed Accounting Standards Update – Liabilities (Topic 405): Obligations Resulting from Joint and Several Liability Arrangements (a consensus of the FASB Emerging Issues Task Force)
  9/14/12 - Comments on a proposed accounting standards update, the objective of which is to provide guidance for the recognition, measurement, and disclosure of obligations resulting from joint and several liability arrangements for which the total amount under the arrangement is fixed at the reporting date, except for obligations addressed within existing guidance in U.S. GAAP.

• Comments to the AICPA on Exposure Draft—AICPA Assurance Services Executive Committee, Emerging Assurance Technologies Task Force, Audit Data Standard
  9/5/12 - Comments on an exposure draft of the AICPA Assurance Services Executive Committee (ASEC), Emerging Assurance Technologies Task Force, entitled Audit Data Standard. ASEC believes that audit data standards would contribute to the efficiency and effectiveness of the audit process.

• Comments to the IRS on the Proposed and Temporary Regulations on the Portability of a Deceased Spousal Unused Exclusion Amount (IRS-REG-141832-11)
  9/4/12 - Comments regarding temporary and proposed regulations that provide guidance on the estate and gift tax applicable exclusion amount, in general, as well as on the applicable requirements for electing portability of a deceased spousal unused exclusion (DSUE) amount to the surviving spouse and on the applicable rules for the surviving spouse’s use of this DSUE amount.

• Comments to the AICPA on Exposure Draft—Omnibus Proposal, AICPA Professional Ethics Division, Proposed Revised and New Interpretations and Proposed Deletion of Ethics Rulings (June 29, 2012)
  8/27/12 - Comments on the Professional Ethics Executive Committee (PEEC) June 29, 2012 Omnibus Exposure Draft - Proposed Revisions to Interpretation 101-3, Proposed New Interpretations 501-11 and 502-6 and Proposed Deletion of Ethics Rulings.

• Comments to the AICPA on Proposed Statements on Standards for Accounting and Review Services (SSARSs) – Association With Unaudited Financial Statements, Compilation of Financial Statements, and Compilation of Financial Statements—Special Considerations
  8/27/12 - Comments on an exposure draft of Proposed Statements on Standards for Accounting and Review Services (SSARSs) – Association With Unaudited Financial Statements, Compilation of Financial Statements, and Compilation of Financial Statements—Special Considerations. The proposed SSARSs would supersede paragraphs 1.05–.06 and 2.01–.64 of SSARS No. 19, SSARS No. 13, SSARS No. 3 and SSARS No. 6, and represent a redrafting to apply the AICPA Accounting and Review Services Committee’s (ARSC’s) clarity drafting conventions.

• NYSSCPA Urges Sen. Gillibrand to Co-sponsor a Bill That Would Modify the Definition of Fiduciary
  8/16/12 – NYSSCPA President Gail M. Kinsella sent a letter to United States Senator Kirsten Gillibrand (D-NY) on August 16 urging her to co-sponsor Senate Bill 1232. The bill would modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) to exclude appraisers of Employee Stock Ownership Plans (ESOPs). 

• NYSSCPA Urges Sen. Schumer to Co-sponsor Tax Return Due Date Simplification Bill
  7/10/12 - NYSSCPA President Gail M. Kinsella sent a letter to United States Senator Charles Schumer (D-NY) on July 10 urging him to co-sponsor Senate Bill 845. The bill would allow partnerships, corporations, trusts, estates, and individuals to better submit timely, accurate returns and reduce the need for extended and amended returns.

• Comments to the PCAOB on Release No. 2012-001 – Proposed Auditing Standard—Related Parties; Proposed Amendments to Certain PCAOB Auditing Standards Regarding Significant Unusual Transactions; and Other Proposed Amendments to PCAOB Auditing Standards
  5/17/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2012-001, a proposed standard that would supersede the PCAOB’s interim standard AU sec. 334, Related Parties. The proposed standard and amendments address evaluation of a company's identification of related party transactions, identifying and evaluating a company's accounting and disclosure of significant unusual transactions and obtaining an understanding of a company's financial relationships and transactions with executive officers sufficient to identify risks of material misstatement.

• Comments to the IRS on RRSP–Late Elections
  5/3/12 - The NYSSCPA International Taxation Committee offered comments to the Internal Revenue Service as it identified the reporting of foreign retirement plans, in particular, Canadian registered retirement savings plans and Canadian registered retirement funds (together referred to as “RRSPs”), held by U.S. persons, as a significant issue that deserves additional attention from Treasury and the IRS in order to lend clarity to their tax treatment.

• Comments on IRS Notice 2011-101 – Transfers by a Trustee From an Irrevocable Trust to Another Irrevocable Trust (Sometimes called “Decanting”); Requests for Comments
  4/19/12 - Response to a request for comments regarding when (and under what circumstances) transfers by a trustee of all or a portion of the principal of an irrevocable trust (Distributing Trust) to another irrevocable trust (Receiving Trust), that result in a change in the beneficial interests in the trust, are not subject to income, gift, estate, or generation-skipping transfer taxes.

• Comments to the IRS on Proposed Regulations REG-130302-10 Reporting of Specified Foreign Financial Assets
  3/19/12 - Comments regarding IRB 2012-8, February 21, 2012, REG-130302-10, Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations Reporting of Specified Foreign Financial Assets (T.D. 9567). Temporary regulations relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest.

• Comments to the FASB on a Proposed Accounting Standards Update (Revised) – Revenue Recognition (Topic 605) Revenue from Contracts with Customers
  3/7/12 - Comments on a proposed accounting standards update (a joint project of FASB and IASB) to clarify the principles for recognizing revenue and to develop a common revenue standard for U.S. GAAP and IFRSs.

• Comments to the PCAOB on Release No. 2011-008—Proposed Auditing Standard on Communications with Audit Committees and Related Amendments to PCAOB Standards
  2/28/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-008 proposing transitional amendments to AU sec. 380, Communication With Audit Committees, and reproposing an auditing standard, Communications with Audit Committees, that would supersede the Board's interim standards AU sec. 380 and AU sec. 310, Appointment of the Independent Auditor, and related amendments to PCAOB standards.

• Comments to the FASB on a Proposed Accounting Standards Update – Real Estate—Investment Property Entities (Topic 973)
  2/10/12 - Comments on a proposed accounting standards update to address the diversity in practice related to entities that invest in real estate. The amendments in this proposed Update would provide accounting guidance for an entity that meets the criteria to be an investment property entity. The proposed amendments also would introduce additional presentation and disclosure requirements for an investment property entity.

• Comments to the FASB on a Proposed Accounting Standards Update – Consolidation (Topic 810) Principal versus Agent Analysis
  2/10/12 - Comments on a proposed accounting standards update of Topic 810, Consolidation. The proposed amendments in this Update would affect all reporting entities that are required to evaluate whether they should consolidate another entity. The proposed amendments are expected to most significantly affect the financial reporting of entities that are involved with variable interest entities.

• Comments to the FASB on a Proposed Accounting Standards Update – Financial Services—Investment Companies (Topic 946), Amendments to the Scope, Measurement, and Disclosure Requirements
  2/10/12 - Comments on a proposed accounting standards update of Topic 946, Financial Services—Investment Companies. The amendments in this proposed Update would affect the scope, measurement, presentation, and disclosure requirements for investment companies in U.S. generally accepted accounting principles (GAAP).

• Comments to the AICPA on a Proposed Statement on Auditing Standards – The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern (Redrafted)
  1/25/12 - Comments on an exposure draft of a proposed statement on auditing standards (SAS). The proposed SAS would supersede SAS No. 59, The Auditor's Consideration of an Entity's Ability to Continue as a Going Concern, as amended (AICPA, Professional Standards, AU sec. 341 and AU-C sec. 570), and represents the redrafting of SAS No. 59 to apply the Auditing Standards Board’s clarity drafting conventions.

• Comments to the AICPA on Exposure Draft—Omnibus Proposal, AICPA Professional Ethics Division, Proposed New Interpretations and Proposed Deletion of Ethics Ruling, November 30, 2011
  1/19/12 - The Professional Ethics Executive Committee (PEEC) is exposing for comment two new interpretations under Rule 505, Form of Organization and Name (AICPA, Professional Standards, ET sec. 505 par. .01). Proposed Interpretation No. 505-4, “Misleading Firm Names,” and proposed Interpretation No. 505-5, “Use of a Common Brand Name in Firm Name,” provide guidance on when firm names would be considered misleading. Also, The PEEC is recommending Ethics Ruling No. 134, “Association of Accountants Not Partners,” of ET section 591, Ethics Rulings on Other Responsibilities and Practices (AICPA, Professional Standards, ET sec. 591, par. .267), be deleted because the guidance contained in proposed Interpretation No. 505-4, “Misleading Firm Names,” would provide members with guidance on misleading firm names.

• Comments to the PCAOB on Release No. 2011-007—Improving the Transparency of Audits: Proposed Amendments to PCAOB Auditing Standards and Form 2
  1/4/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-007, proposed amendments to PCAOB standards that would: (1) require registered public accounting firms to disclose the name of the engagement partner, (2) amend the Annual Report Form to require firms to disclose the name of the engagement partner for each audit report already required to be reported on the form, and (3) require disclosure in the audit report of other independent public accounting firms and other persons that took part in the audit.

2011 - Back to Top

• Comments to the PCAOB on Release No. 2011-006—Concept Release on Auditor Independence and Audit Firm Rotation
  12/13/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-006, a concept release to solicit public comment on ways that auditor independence, objectivity and professional skepticism could be enhanced, including the possible approach of mandatory audit firm rotation.

• Letter to Financial Accounting Foundation (FAF) to provide comments on its Board of Trustees Plan to Establish the Private Company Standards Improvement Council.
  12/12/11 - The NYSSCPA President’s letter to the FAF acknowledging the need to improve the financial reporting of private companies calling for an autonomous standard-setting body to implement differential standards for private companies that is not subject to FASB ratification.

• Comments to the Financial Crimes Enforcement Network, Department of the Treasury: Bank Secrecy Act Regulations; Definition of ‘‘Monetary Instrument’’ (31 CFR Part 1010) Docket Number FINCEN–2011–0003 RIN 1506–AB13
  12/6/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to amend the definition of “monetary instrument'' in the Bank Secrecy Act (``BSA'') regulations for purposes of the international transport of currency and monetary instrument reporting requirement to include tangible prepaid access devices.
• Comments to the IRS on Notice 2011-82 — Guidance on Electing Portability of Deceased Spousal Unused Exclusion Amount.
  10/21/11 - Response to IRS Notice 2011-82 inviting public comments on specific issues which have been identified for consideration in proposed regulations to be issued under section 2010(c).

• Comments to the FASB on a Proposed Accounting Standards Update – Property, Plant, and Equipment (Topic 360) Derecognition of in Substance Real Estate—a Scope Clarification
  9/27/11 - Comments on a proposed accounting standards update, the objective of which is to resolve the diversity in practice about whether the guidance in Subtopic 360-20 applies to a parent that ceases to have a controlling financial interest in a subsidiary that is in substance real estate as a result of default on the subsidiary’s nonrecourse debt.

• Comments to the PCAOB on Release No. 2011-003 – Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements and Related Amendments to PCAOB Standards
  9/27/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-003, a concept release to solicit public comment on the potential direction of a proposed standard-setting project on the content and form of reports on audited financial statements, specifically potential changes to the auditor's reporting model based on concerns of investors and other financial statement users.

• Comments to IAASB on IAASB Consultation Paper – Enhancing the Value of Auditor Reporting: Exploring Options for Change
  9/14/11 - NYSSCPA response to a request by the International Auditing and Assurance Standards Board (IAASB) for comments on a consultation paper that seeks to determine whether there are common views among users of audited financial statements and other stakeholders about the usefulness of auditor reporting.

• Comments to the Financial Accounting Foundation on the Recommendations of the Blue-Ribbon Panel on Standard Setting for Private Companies to the Board of Trustees of the Financial Accounting Foundation.
  7/28/11 - Comments on recommendations made by the Blue-Ribbon Panel on Private Company Financial Reporting to the Financial Accounting Foundation regarding differential standards and a separate standard-setting entity for private companies.

• Comments to the SEC on Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers
  7/28/11 - Comments to the Securities and Exchange Commission on an SEC Staff Paper: Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers – Exploring a Possible Method of Incorporation (May 26, 2011).

• Comments to the IRS on Notice 2011-48 – Registered Tax Return Preparer Competency Examination
  7/1/11 - Comments to the IRS in response to IRS Notice 2011-48 inviting public comments on the content and administration of the registered tax return preparer competency examination.

• Letter to NYS Governor Andrew M. Cuomo Recommending Signing Bill A.4881-B/S.2628-A into Law to Bring Cross Border Practice Privilege into New York’s Public Accountancy Law
  6/30/11 - Letter to NYS Governor Andrew M. Cuomo recommending the signing into law of bill A.4881-B/S.2628-A to grant cross-border practice mobility in accordance with Section 23 of the Model Uniform Accountancy Act.

• Comments to the FASB on a Proposed Accounting Standards Update – Intangibles—Goodwill and Other (Topic 350), Testing Goodwill for Impairment
  6/6/11 - Comments on a proposed accounting standards update, the objective of which is to simplify how an entity is required to test goodwill for impairment by permitting a qualitative assessment.

• Comments to IAASB on IAASB Discussion Paper – The Evolving Nature of Financial Reporting: Disclosure and Its Audit Implications
  5/31/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on a discussion paper that explores issues and perspectives regarding financial statement disclosures and auditing disclosures in a financial statement audit.

• Comments to the IRS on Basis Reporting by Securities Brokers and Basis Determination for Stock
  5/31/11 - Comments to the IRS indicating circumstances in which additional guidance might be beneficial with respect regulations on basis reporting by securities brokers and basis determination for stock (Final Regulations 1.1012-1(c)(10), 1.1012-1(e)(12), 1.6045A-1(d), 1.6045B-1(g)).

• Comments to the IRS – Recommendations to Improve Tax Reporting (Due Dates)
  5/23/11 - Recommendations to the IRS to improve tax reporting, specifically, recommendations on changes to certain tax filing due dates.

• Comments to the IRS on Their Interpretation of Regulations on Basis of S Corporation Stock
  5/23/11 - Comments to the IRS regarding the effect on an S corporation shareholder’s stock basis of prior year losses that were not deductible because of the basis limitation on deductibility of losses.

• Comments to the FASB on a Proposed Accounting Standards Update–Balance Sheet (Topic 210) Offsetting
  4/27/11 - Comments on a proposed accounting standards update addressing the differences in the offsetting (netting) requirements in U.S. GAAP and IFRSs.

• Comments to the FASB on a Discussion Paper–Selected Issues about Hedge Accounting (Including IASB Exposure Draft Hedge Accounting)
  4/27/11 - Response to an invitation to comment, issued by the FASB and IASB, on their discussion paper considering how best to improve and simplify standards for financial reporting of financial instruments, and, at the same time, provide users with clearer and more complete information.

• Comments to IAASB Regarding an IAASB Consultation Paper – Proposed IAASB Strategy and Work Program for 2012–2014
  4/4/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on the proposed IAASB Strategy and Work Program for 2012 – 2014.

• Comments to the FASB on Supplementary Document – Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities: Impairment
  4/1/11 - Comments to the FASB on this Supplementary Document, issued by the FASB as a step preceding the development of an Exposure Draft of a proposed Accounting Standards Update. This supplementary document presents an impairment model that the FASB and IASB believe will enable them to satisfy at least part of their individual objectives for impairment accounting while achieving a common solution to impairment.

• Letter to NYC Department of Finance Commissioner Frankel Regarding the Tax Representatives and Practitioners Program (TaxRAPP)
  2/16/11 - Letter to New York City Department of Finance Commissioner Frankel requesting resumption of the Tax Representatives and Practitioners Program (TaxRAPP), noting its benefit to both practitioners and the department.

• Comments to IAASB – Proposals Relating to International Auditing Practice Statements (IAPSs) and the Proposed International Auditing Practice Statement, IAPS 1000, Special Considerations in Auditing Complex Financial Instruments
  2/11/11 - Comments on proposals relating to International Auditing Practice Statements (IAPSs) including withdrawal of existing IAPSs, clarification of the status and authority of new IAPSs, proposed amendments to the Preface to the International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements, and Proposed International Auditing Practice Statement IAPSs 1000, Special Considerations in Auditing Complex Financial Instruments.

• Letter to NYS Governor Andrew M. Cuomo Recommending That the Office of the New York State Taxpayer Rights Advocate Be Continued
  2/7/11 - Letter to NYS Governor Andrew M. Cuomo recommending the continuation of the Office of the New York State Taxpayer Rights Advocate, that its role be codified, and suggestions as to its term, reporting, and other aspects.

• Comments to the AICPA on Proposed Revised Statement on Auditing Standards, Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country
  1/31/11 - Comments to the AICPA on a Proposed Revised Statement on Auditing Standards, Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country. This proposed revised SAS would supersede SAS No. 51, Reporting on Financial Statements Prepared for Use in Other Countries (AICPA, Professional Standards, vol. 1, AU sec. 534).

• Comments to the FASB on Proposed Accounting Standards Update – Transfers and Servicing (Topic 860) Reconsideration of Effective Control for Repurchase Agreements
  1/12/11 - Comments to the FASB on a Proposed Accounting Standards Update – Transfers and Servicing (Topic 860) Reconsideration of Effective Control for Repurchase Agreements. The objective of the proposed update is to improve the accounting for repurchase agreements (repos) and other agreements that both entitle and obligate a transferor to repurchase or redeem financial assets before their maturity.