Archived Committee Comment Letters
Comment Letters issued by AP & AS on professional standards exposure drafts
Letters organized by year
2018
September 19, 2018—Proposed Accounting Standards Update: Codification Improvements to Topic 326 - Financial Instruments – Credit Losses
September 12, 2018—Proposed Accounting Standards Update: Leases (Topic 842) Narrow-Scope Improvements for Lessors
August 9, 2018—Proposed Accounting Standards Update: Not-for-Profit (Topic 958) Updating the Definition of Collections
June 8, 2018—Proposed Accounting Standards Update: Collaborative Arrangements (Topic 808) Targeted Improvements
May 15, 2018—Proposed Statement on Auditing Standards – Auditor Reporting
March 23, 2018—Proposed Accounting Standards Update: Derivatives and Hedging (Topic 815)
January 31, 2018—Proposed Accounting Standards Update: Leases (Topic 842)
January 31, 2018—Proposed Accounting Standards Update: Income Statement—Reporting Comprehensive Income (Topic 220)
2017
October 30, 2017—Proposed Accounting Standards Update: Not-for-Profit Entities (Topic 958)
Clarifying the Scope and the Accounting Guidance for Contributions Received and Contributions Made
October 20, 2017—Proposed Accounting Standards Update: Leases (Topic 842) Land Easement Practical Expedient for Transition to Topic 842
February 27, 2017—Proposed Accounting Standards Update Debt (Topic 470) Simplifying the Classification of Debt in a Classified Balance Sheet (Current versus Noncurrent)
February 27, 2017—Proposed Accounting Standards Update Inventory (Topic 330) Disclosure Framework—Changes to the Disclosure Requirements for Inventory
February 1, 2017—Proposed Accounting Standards Update: Distinguishing Liabilities from Equity (Topic 480)
2016
December 21, 2016—Proposed Accounting Standards Update: Compensation—Stock Compensation (Topic 718) Scope of Modification Accounting
November 16, 2016—Receivables — Nonrefundable Fees and Other Costs (Subtopic 310-20) Premium Amortization on Purchased Callable Debt Securities
November 16, 2016—Derivatives and Hedging (Topic 815) Targeted Improvements to Accounting for Hedging Activities
November 10, 2016—Proposed Statement of Financial Accounting Concepts Concepts Statement 8 – Conceptual Framework for Financial Reporting – Chapter 7: Presentation
September 22, 2016—Proposed Accounting Standards Update, Not-for-Profit Entities–Consolidation (Subtopic 958-810): Clarifying When a Not-for-Profit Entity That Is a General Partner Should Consolidate a For-Profit Limited Partnership or Similar Entity
September 23, 2016—Employee Benefit Plan Master Trust Reporting (EITF 16B)
August 8, 2016—Comments on PCAOB Rulemaking Docket Matter No. 034 Proposed Auditing Standard – The Auditor’s Report on an Audit of Financial Statements when the Auditor Expresses an Unqualified Opinion and Related Amendments to PCAOB Standards
July 21, 2016—Comments on PCAOB Rulemaking Docket Matter No. 042 Proposed Amendments Relating to the Supervision of Audits Involving Other Auditors, and Proposed Auditing Standard – Dividing Responsibility for the Audit with Another Accounting Firm
July 20, 2016—Consolidation (Topic 810) Interests Held through Related Parties That Are under Common Control
June 27, 2016—File Reference No. EITF-16A: Proposed Accounting Standards Update - Statement of Cash Flows (Topic 230): Restricted Cash
June 22, 2016—Intangibles—Goodwill and Other (Topic 350) Simplifying the Accounting for Goodwill Impairment
May 31, 2016—Retrieval of Standards for Nonpublic Entities
April 13, 2016—Proposed Accounting Standards Update: Compensation—Retirement Benefits (Topic 715) Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost
April 13, 2016—Proposed Accounting Standards Update: Compensation—Retirement Benefits—Defined Benefit Plans—General (Subtopic 715-20) Changes to the Disclosure Requirements for Defined Benefit Plans
March 25, 2016—Proposed Accounting Standards Update: Statement of Cash Flows (Topic 230)
February 19, 2016—Proposed Accounting Standards Update: Fair Value Measurement (Topic 820) Disclosure Framework—Changes to the Disclosure Requirements for Fair Value Measurement
February 8, 2016—Proposed Accounting Standards Update: Government Assistance (Topic 832) Disclosures by Business Entities about Government Assistance
January 22, 2016—Proposed Accounting Standards Update: Business Combinations (Topic 805) Clarifying the Definition of a Business
2015
November 13, 2015—Revenue from Contracts with Customers (Topic 606) Narrow-Scope Improvements and Practical Expedients
August 18, 2015—Not-for-profit Entities (Topic 958) and Health Care Entities (Topic 954): Presentation of Financial Statements of Not-for-Profit Entities
July 28, 2015—PCAOB Staff Consultation Paper No. 2015-01 The Auditor’s Use Of The Work Of Specialists May 28, 2015
July 24, 2015—Investments—Equity Method and Joint Ventures (Topic 323) Simplifying the Equity Method of Accounting
July 24, 2015—Compensation—Stock Compensation (Topic 718) Improvements to Employee Share-Based Payment Accounting
June 26, 2015—Business Combinations (Topic 805) Simplifying the Accounting for Measurement-Period Adjustments
June 26, 2015—Revenue from Contracts with Customers (Topic 606) Identifying Performance Obligations and Licensing
May 18, 2015—Revenue Recognition
May 18, 2015—File Reference Nos. EITF-15C – I, EITF-15C – II, and EITF-15C – III Plan Accounting: Defined Benefit Pension Plans (Topic 960) Defined Contribution Pension Plans (Topic 962) Health and Welfare Benefit Plans (Topic 965)
May 18, 2015—Liabilities – Extinguishments of Liabilities (Subtopic 405-20)
May 18, 2015—Derivatives and Hedging (Topic 815)
May 18, 2015—Three Year Review of the Private Company Council: Request for Comment
April 22, 2015—Derivatives and Hedging (Topic 815) Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives
April 8, 2015—Income Taxes (Topic 740) Intra-Entity Asset Transfers
April 8, 2015—Income Taxes (Topic 740) Balance Sheet Classification of Deferred Taxes
February 12, 2015—Financial Services—Investment Companies (Topic 946) Disclosures about Investments in Other Investment Companies
2014
November 21, 2014—Compensation—Retirement Benefits (Topic 715) Practical Expedient for the Measurement Date of an Employer’s Defined Benefit Obligation and Plan Assets
November 18, 2014—Interest—Imputation of Interest (Subtopic 835-30) Simplifying the Presentation of Debt Issuance Cost
November 14, 2014—Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40) Customer’s Accounting for Fees Paid in a Cloud Computing Arrangement
October 29, 2014—Staff Consultation Paper, Auditing Accounting Estimates and Fair Value Measurements
October 16, 2014—Feedback Regarding the AICPA’s Discussion Paper: Enhancing Audit Quality 2013 FASB
2013
September 6, 2013—File Reference No. 2013-270 Leases (Topic 840)
August 30, 2013—FASB – Proposed Accounting Standards Update: Presentation of Financial Statements (Topic 205); Reporting Discontinued Operations
August 16, 2013—FASB – Proposed Accounting Standards Update: Derivatives and Hedging (Topic 815) Accounting for Certain Receive-Variable, Pay-Fixed Interest Rate Swaps
August 15, 2013—FASB – Proposed Accounting Standards Update: Intangibles Goodwill and Other (Topic 350) Accounting for Goodwill
August 15, 2013—FASB – Proposed Accounting Standards Update: Business Combinations (Topic 805) Accounting for Identifiable Intangible Assets in a Business Combination
July 10, 2013—AICPA – Auditing Standards Board Exposure Draft Using the Work of Internal Auditors
July 3, 2013—PCAOB – PCAOB Rulemaking Docket Matter No. 038 – Proposed Auditing Standard-Related Parties, Proposed Amendments to Certain PCAOB Auditing Standards Regarding Significant Unusual Transactions and Other Proposed Amendments to PCAOB Auditing Standards
June 28, 2013—IASB – Exposure Draft ED/2013/3 Financial Instruments: Expected Credit Losses –
May 31, 2013—IASB – Exposure Draft ED 2013/4 Defined Benefit Plans: Employee Contributions (Proposed amendments to IAS 19)
May 22, 2013—FASB – Private Company Decision-Making Framework
May 22, 2013—FASB – Investments—Equity Method and Joint Ventures (Topic 323) Accounting for Investments in Qualified Affordable Housing Projects, a consensus of the FASB Emerging Issues Task Force
May 22, 2013—PCAOB – PCAOB Rulemaking Docket Matter No. 40 – Proposed Framework for Reorganization of PCAOB Auditing Standards
May 15, 2013—FASB – Proposed Accounting Standards Update: Financial Instruments – Overall; Recognition and Measurement of Financial Assets and Financial Liabilities (Subtopic 825-10)
May 15, 2013—AICPA – Proposed Statements on Standards for Accounting and Review Services, Review of Financial Statements, Review of Financial Statements – Special Considerations
April 22, 2013—FASB – Proposed Accounting Standards Update: Financial Instruments—Credit Losses (Subtopic 825-15)
March 31, 2013—IASB – Exposure Draft: ED 2012/4: Classification and Measurement: Limited Amendments to IFRS 9: Proposed amendments to IFRS 9 (2010)
March 21, 2013—IASB – Exposure Draft ED/2013/2: Novation of Derivatives and Continuation of Hedge Accounting (Proposed Amendments to IAS 39 and IFRS 9)
February 8, 2013—PCC – U.S. GAAP for Private Companies
January 23, 2013—AICPA – Proposed Financial Reporting Framework for Small-and Medium-Sized Entities (the "FRF" and "SMEs")
January 22, 2013—FASB – Proposed Accounting Standards Update: Financial Instruments (Topic 825) Clarifying the Scope and Applicability of a Particular Disclosure to Nonpublic Entities
2012
December 18, 2012—IASB – Exposure Draft ED/2012/5 Clarification of Acceptable Methods of Depreciation and Amortization, Proposed amendments to IAS 16 and IAS 38
December 18, 2012—IASB – Exposure Draft ED/2012/3 Equity Method: Share of Other Net Asset Changes, Proposed amendments to IAS 28
December 14, 2012—IESBA – Responding to Suspected Illegal Act
November 27, 2012—FASB – File Reference No. 2012-220 – Discussion Paper on Disclosure Framework
November 26, 2012—AICPA – Proposed Statements On Standards For Accounting And Review Services: Association With Unaudited Financial Statements; Compilation Of Financial Statements; Compilation Of Financial Statements Special Considerations
October 25, 2012—FASB – Private Company Decision-Making Framework
September 14, 2012—FASB – Proposed Accounting Standards Update: Financial Instruments (Topic 825); Disclosures about Liquidity Risk and Interest Rate Risk
September 12, 2012—FASB – Proposed Accounting Standards Update: Comprehensive Income (Topic 220); Presentation of Items Reclassified Out of Accumulated Other Comprehensive Income
September 12, 2012—IASB – Comprehensive Review of the IFRS for SMEs
September 7, 2012—AICPA – Proposed Statement on Auditing Standards – Omnibus Statement on Auditing Standards - 2012
September 7, 2012—IAASB – Improving the Auditor’s Report – Invitation to Comment –
September 7, 2012—FASB – Proposed Accounting Standards Update: Presentation of Financial Statements (Topic 205), The Liquidation Basis of Accounting
May 10, 2012—PCAOB – Proposed Auditing Standard – Related Parties, Proposed Amendments to Certain PCAOB Auditing Standards Regarding Significant Unusual Transactions, and Other Proposed Amendments to PCAOB Auditing Standards; PCAOB Release No. 2012-001; February 28, 2012; PCAOB Rulemaking Docket Matter No. 038
February 15, 2012—FASB – Proposed Accounting Standards Update: Parent's Accounting for the Cumulative Translation Adjustment upon the Sale or Transfer of a Group of Assets That Is a Nonprofit Activity or a Business within a Consolidated Foreign Entity; A consensus of the FASB Emerging Issues Task - File Reference No. EITF-11A
February 15, 2012—FASB – Proposed Accounting Standards Update, Intangibles-Goodwill and Other (Topic 350), Testing Indefinite-Lived Intangibles for Impairment
February 15, 2012—FASB – Proposed Accounting Standards Update (Revised), Revenue Recognition (Topic 605), Revenue from Contracts with Customers
February 14, 2012—PCAOB – Proposed Auditing Standard Related to Communications With Audit Committees; Related Amendments to PCAOB Standards; and Transitional Amendments; PCAOB Release No. 2011-008; December 20, 2011; PCAOB Rulemaking Docket Matter No. 030
February 14, 2012—FASB – Proposed Accounting Standards Update: Real Estate – Investment Property Entities (Topic 973)
January 7, 2012—FASB – File Reference No. 2011-220; Consolidation (Topic 810): Principal versus Agent Analysis
2011
December 29, 2011—FASB – File Reference No. 2011-200; Proposed Accounting Standards Update: Financial Services – Investment Companies (Topic 946) Amendments to the Scope, Measurement, and Disclosure Requirements
December 21, 2011—PCAOB – Improving the Transparency of Audits: Proposed Amendments to PCAOB Auditing Standards and Form 2: PCAOB Release No. 2011-007; October 11, 2011; PCAOB Rulemaking Docket Matter No. 29
December 15, 2011—PCC – Plan to Establish the Private Company Standards Improvement Council
December 9, 2011—PCAOB – Concept Release on Auditor Independence and Audit Firm Rotation: PCAOB Release No. 2011-006; August 16, 2011; PCAOB Rulemaking Docket Matter No. 37
September 27, 2011—PCAOB – PCAOB Release No. 2011-003; Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements
September 7, 2011—FASB – Exposure Draft of Proposed Accounting Standards Update, Property, Plant and Equipment (Topic 360), Derecognition of in Substance Real Estate – a Scope Clarification (File Reference No. EITF-100E
