Comment Letters

2020 - Back to Top

• Comments to the IFRS Foundation - Discussion Paper DP/2020/1: Business Combinations – Disclosures, Goodwill and Impairment
  12/28/20 Comments on an IFRS Foundation discussion paper on possible improvements to the information companies report about acquisitions of businesses to help investors assess how successful those acquisitions have been, and on how companies should account for goodwill arising from such transactions.
• Comments to the IFRS Foundation - Consultation Paper on Sustainability Reporting
  12/22/20 Comments on an IFRS Foundation consultation paper issued to identify the demand from stakeholders in the area of sustainability reporting and understand what the Foundation could do in response to that demand.
• Comments to the FASB on a Proposed Accounting Standards Update – Modifications of Equity Instruments
  12/18/20 Comments on a proposed accounting standards update - Earnings Per Share (Topic 260), Debt—Modifications and Extinguishments (Subtopic 470-50), Compensation—Stock Compensation (Topic 718), and Derivatives and Hedging—Contracts in Entity’s Own Equity (Subtopic 815-40): Issuer’s Accounting for Certain Modifications or Exchanges of Freestanding Equity-Classified Forwards and Options (a consensus of the Emerging Issues Task Force).
• Comments to AICPA PEEC on an Exposure Draft, Proposed Interpretation—Staff Augmentation Arrangements
  11/30/20 Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of a proposed interpretation for “Staff Augmentation Arrangements” that indicates such arrangements will impair independence except when certain safeguards are in place.
• Comments to the FASB on a Proposed Accounting Standards Update – Leases (Topic 842): Targeted Improvements
  11/23/20 Comments on a proposed accounting standards update that is part of FASB's post implementation review of Topic 842 to address implementation issues encountered by public business entities.
• Comments to the FASB on a Proposed Accounting Standards Update – Franchisors—Revenue from Contracts with Customers (Subtopic 952-606): Practical Expedient
  10/29/20 Comments on a proposed accounting standards update intended to address the practical challenges arising from the adoption of Topic 606 and, where prudent, provide effective date delays and practical expedients to facilitate a smooth transition to the new standard.
• Comments to the FASB on a Proposed Statement of Financial Accounting Concepts—Concepts Statement 8—Conceptual Framework for Financial Reporting—Chapter 4: Elements of Financial Statements
  10/29/20 Comments on a proposed statement of financial accounting concepts chapter that would provide the FASB with a framework for developing standards by identifying elements of financial statements that could be appropriate for recognition in the financial statements and relevant to the users of those financial statements.
• Comments to the FASB on a Proposed Statement of Financial Accounting Concepts—Concepts Statement 8—Conceptual Framework for Financial Reporting—Chapter 4: Elements of Financial Statements
  10/1/20 Comments to the IAASB on Proposed ISA 600 (Revised) that is intended to strengthen the auditor’s approach to planning and performing a group audit and to clarify the interaction between ISA 600 and the other ISAs.
• Comments to the IASB on IFRS Standards Exposure Draft—General Presentation and Disclosures
  9/23/20 Comments on an IFRS exposure draft on general presentation and disclosure intended to make financial information more useful and improving the way the financial information, in the case of financial performance, is communicated to financial statement users.
• Comments to AICPA PEEC on an Exposure Draft, Proposed Revised Interpretation—Records Requests
  9/18/20 Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their exposure draft of a proposed revised interpretation to help members better understand their ethical responsibilities with respect to requests for records.
• Comments to the FASB on a Proposed Accounting Standards Update – Compensation—Stock Compensation (Topic 718): Determining the Current Price of an Underlying Share for Equity-Classified Share-Option Awards
  9/18/20 Comments on a proposed accounting standards update intended to address stakeholder concern that determining the fair value of private company traditional stock-option awards (share-option awards) at grant date or upon a modification to an award is often costly and complex.
• Comments to NASBA on Proposed Revisions to the Uniform Accountancy Act’s Model Rules on Education
  8/25/20 Comments to the National Association of State Boards of Accountancy (NASBA) on proposed revisions to the Uniform Accountancy Act’s Model Rules that pertain to education. The revisions were developed by the AICPA/NASBA CPA Evolution Initiative and reviewed by the NASBA Uniform Accountancy Act Committee and released for comment.
• Comments to the SEC on Proposed Rule 2a-5, Good Faith Determinations of Fair Value
  7/22/20 Comments to the SEC on a proposed a new rule (2a-5) under the Investment Company Act of 1940 that would address valuation practices and the role of the board of directors with respect to the fair value of the investments of a registered investment company or business development company.
• Comments to the IESBA on an Exposure Draft – Proposed Revisions to the Non-Assurance Services Provisions of the Code
  5/20/20 Comments to the International Ethics Standards Board for Accountants on proposed enhanced guidance to assist firms in evaluating the level of threats to independence when providing NAS to audit clients.
• Comments to the IESBA on an Exposure Draft – Proposed Revisions to the Fee-related Provisions of the Code
  5/20/20 Comments to the International Ethics Standards Board for Accountants on proposed enhanced guidance on identifying, evaluating and addressing threats to independence in relation to fee-related matters.
• Comments to the AICPA - Maintaining the Relevance of the Uniform CPA Examination®: An Exposure Draft and Invitation to Comment
  5/15/20 Comments to the AICPA on a combined Exposure Draft and Invitation to Comment presenting the findings and conclusions of a practice analysis conducted by the AICPA Examinations Team focused on the impact of technology on the work of newly licensed CPAs and the identification of areas where the CPA Exam has become too broad and not sufficiently focused.
• Comments to the FASB on a Proposed Accounting Standards Update – Revenue from Contracts with Customers (Topic 606) and Leases (Topic 842): Effective Dates for Certain Entities
  4/27/20 Comments on a proposed accounting standards update proposing a limited deferral of the effective dates for certain entities for ASU No. 2014-09, Revenue from Contracts with Customers (Topic 606) (Revenue) and ASU No. 2016-02, Leases (Topic 842) (Leases) due to the COVID-19 pandemic.
• Comments to the FASB on a Proposed Accounting Standards Update – Not-for-Profit Entities (Topic 958): Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets
  4/6/20 Comments on a proposed accounting standards update to address stakeholders’ concerns about the lack of transparency about the valuation of contributed nonfinancial assets received by NFPs, as well as the amount of those contributions used in an NFP’s programs and other activities.
• Comments on PCAOB Release No. 2019-003 - Potential Approach to Revisions to PCAOB Quality Control Standards
  3/17/20 Comments to the Public Company Accounting Oversight Board (PCAOB) on their concept release on a potential approach to revising the PCAOB's quality control standards.and what changes it might propose in the future to strengthen the PCAOB's requirements for audit firms' quality control systems.
• Comments to the IESBA on an Exposure Draft – Proposed Revision to the Code, Addressing the Objectivity of Engagement Quality Reviewers
  3/13/20 Comments to the International Ethics Standards Board for Accountants on proposed guidance on the application of the conceptual framework in the Code to address the topic of the objectivity of an engagement quality reviewer (EQR), thereby supporting proposed ISQM 2 in addressing the matter of the eligibility of an individual to serve in an EQR role.
• Comments to the SEC on Proposed Amendments to Rule 2-01, Qualification of Accountants
  3/13/20 Comments to the SEC on proposed amendments to update certain auditor independence requirements. The proposed amendments are intended to more effectively focus the independence analysis on those relationships or services that are more likely to pose threats to an auditor’s objectivity and impartiality.
• Comments to AICPA PEEC on a Consultation Paper—Strategy and Work Plan
  2/26/20 Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their consultation paper on the AICPA Professional Ethics Division’s strategy for the next three years.
• Comments to the FASB on a Proposed Accounting Standards Update – Derivatives and Hedging (Topic 815): Codification Improvements to Hedge Accounting
  1/2/20 Comments on a proposed accounting standards update that identifies certain areas that require clarification to better align those areas with the objectives articulated in Update 2017-12, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities.

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.