July 21, 2018

comment letters

The PCAOB’s Valentine’s Day Gift to Us is More Time to Comment on Partner Naming

Compliance Week has our friendly reminder that if you have something to say about audit partner naming, you better speak now or forever hold your peace: As preparers wrap up their year-end financial reports, they'll have a few extra weeks to make their views known on a proposal to begin naming engagement partners in the […]

More PCAOB Comment Letters Need to Complain About the Issuer-pay Model

If you're like us, you've been anxiously awaiting comment letters on the PCAOB's auditor reporting model proposal. There's nothing better than self-righteous firms penning letters filled with thinly-veiled condescension. Plus, the U.S. Chamber owes us all an honest effort after phoning in their initial response.    So far none of the major accounting firms, the AICPA, CAQ, […]

Confession: We Have a Mad Crush on Susan S. Coffey, CPA

Consider this our official admission that we’ve got the hots for Susan Coffey of the AICPA (not to be confused with this Susan Coffey, who also happens to be a hottie).

Suddenly we’re really into anything she has to say, made even more addic��������������������point on international standards and affinity for acronyms that no one can keep up with. We like that in a woman. “Please note that the AICPA supports international standards and believes in adoption as an ultimate goal, but requiring adoption at this time is unrealistic.” Talk about a siren’s call.

Suz isn’t really in the news too much (most of the face time goes to Barry Melancon) but we managed to find a recent comment letter to the Senior Technical Manager of the Compliance Program at the International Federation of Accountants that she wrote:

May 31, 2011
Senior Technical Manager
Compliance Program
International Federation of Accountants
545 Fifth Avenue, 14th Floor
New York, New York 10017

Dear Senior Technical Manager,

The American Institute of CPAs (AICPA) is pleased to comment on the IFAC exposure, Proposed IFAC Member Body Compliance Program Strategy 2011-2014.

We applaud the Compliance Advisory Panel’s (CAP) effort to provide a work plan and timeline to the Terms of Reference (TOR) approved by the IFAC Board in September 2008 for future CAP activities. These activities continue to enhance the Member Body Compliance Program and meet the expectations of the Public Interest Oversight Board (PIOB) in its oversight of CAP, as an important public interest activity committee (PIAC) within IFAC.

[Six sentences filled with so many acronyms that it reads like 1st Grader’s handwriting class.]

The new concept of “adoption” suggests that member bodies and/or their country’s governments should turn over their role in standard-setting for the profession to international groups without question. We submit that this approach is not acceptable in current international and national political environments. Therefore, CAP should not require IFAC member bodies to achieve a level that is not practical nor realistic, setting up the Member Body Compliance Program for failure. [Do we have a dominatrix on our hands?]

We feel strongly that the current Best Endeavors goal with its convergence objective is currently working and should continue without any further consideration of elevating this benchmark to total adoption. Please note that the AICPA supports international standards and believes in adoption as an ultimate goal, but requiring adoption at this time is unrealistic [Adrienne is fanning herself]. This would create a situation where most member bodies would be in violation of the IFAC Compliance Program and would continue in violation for the foreseeable future.

Thank you for the opportunity to comment on this important exposure, and we appreciate your consideration of our concern.

Sincerely,
Susan S. Coffey, CPA
Senior Vice President
Member Quality and International Affairs

So not exactly Hafiz but we’re still smitten. How did this CPA-soaked Cupid’s arrow strike us, you ask? Adrienne saw her speak at AICPA Spring Council and was completely in awe from even before she said, “Good afternoon, I’m Susan Coffey.” As she was debriefing me about Tom Hood’s boyish charms and whatnot, I happened to ask if there were any females that had any qualities prized by the superficial man. Of course that’s when she launched into Ms. Coffey’s speech at the Council. She couldn’t really remember what was being said but then she pointed me to her picture and then our conversation turned to a possible future hottie contest on GC (Susan would be a #1 seed, natch) that has yet to develop.

ANYWAY, we’ve discussed this crush at length and we decided it was time that we jointly confess our affections to the GC faithful. What do we exactly do we want to accomplish with this admission? Drinks and appetizers would probably be a good start. Getting in touch, Susan, is easy. Email us here.

Now that we’ve sufficiently put ourselves out there, dear readers, feel free to send us any nominations you have for accountants that you’d like to see in a future hottie contest. We’ll do the appropriate due diligence once we feel that enough worthy candidates have been submitted but just know that Ms. Coffey will be in field.

‘Dear friends at the FASB: I am concerned that you good folks have lost touch with reality’

Today, in cheeky comment letters to accounting rulemakers.

FASB Letter_good Folks

Without Blaming Lehman Directly, FASB Solicits Comments on a Repo Accounting Do-Over

Filed under: more mess to directly blame on the fall of Lehman Brothers and Uncle Ernie’s epic failure

FASB is being awfully kind to those who played a large part in that whole total financial meltdown issue by avoiding actual name-dropping in their latest exposure draft but we don’t need names to know who they are talking about. *coughLehmancough* Here’s the note from FASB yesterday:

The Financial Accounting Standards Board (FASB) issued an Exposure Draft (ED) today to solicit input from stakeholders on its proposal 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. The FASB requests comments on this ED by January 15, 2011.

“During the global economic crisis, concerns were expressed about a narrow aspect of existing guidance for determining whether a repo should be accounted for as a sale or as a secured borrowing,” notes FASB Acting Chairman Leslie F. Seidman. “The proposals contained in this Exposure Draft seek to address these concerns by simplifying this guidance.”

You hear that? You’ve got until January 15th to draw up your fantastic comment letters (please don’t disappoint us, we haven’t seen a good comment letter since North Carolina State Employees’ Credit Union President James Blaine said of mark-to-market: “Theoretically arrogant; in practice insane; financially negligent and reckless. Other than that, I have no concerns.”) on this new repo accounting proposal.

Once again, FASB wants the input of the worker grunts to find out A) what the plan is and B) how they should go about implementing it.

Seeing as how comment letters are a hallmark of our fantastically cooperative profession maybe FASB is going about this the wrong way. After all, it would be the investors who relied on incorrect information on Lehman’s financial condition based on creative repo accounting (mind you, “creative” and “fraudulent” are not the same thing) who are most impacted by current rules and any changes, not the accountants putting together the financial statements. Surely they would know better than to rely on their own financial information.

If you are unfamiliar with the joys of repo accounting FASB has offered a quick primer:

In a typical repo transaction, an entity transfers financial assets to a counterparty in exchange for cash with an agreement for the counterparty to return the same or equivalent financial assets for a fixed price in the future. Topic 860, Transfers and Servicing, prescribes when an entity may or may not recognize a sale upon the transfer of financial assets subject to repo agreements. That determination is based, in part, on whether the entity has maintained effective control over the transferred financial assets.

The amendments in this proposed Update are intended to simplify the accounting for these transactions by removing from the assessment of effective control the criterion requiring the transferor to have the ability to repurchase or redeem the financial assets, as well as implementation guidance related to that criterion.

Clarification is always nice, I guess, but paint me skeptical, I don’t see additional guidance doing much for closing the giant gaping loophole that Lehman drove a truck through on its way right off the cliff.

If You Never Write Another FASB Comment Letter In Your Life…

… please answer this with your best explanation of your position. I’ll go on record saying I am expecting comment letters stuffed with expletives, paranoia, panic and conjecture and personally can’t wait to read some of them.

“Quirky” representatives of the Profession, you know who you are. I want long rambling anti-IFRS manifestos dammit, don’t disappoint me.

Your mission:

The Financial Accounting Standards Board (FASB or Board) is issuing this Discussion Paper to solicit information from stakeholders about the time and effort that will be involved in adapting to several anticipated new accounting and reporting standards and when those standards should become effective. The FASB will use that information to develop an implementation plan for those new standards that helps stakeholders manage the pace and cost of change. The FASB requests comments on this Discussion Paper by January 31, 2011.

The question FASB would like answered is “how the fuck are we going to pay for this convergence thing?” and they’re asking the profession to come up with solutions. I imagine some pockets of the profession couldn’t care less how much it will cost as they are only thinking about learning the new rules because, well, someone’s got to do it, right?

Don’t misunderstand it, they would also like to know if they should transition all at once or gradually, if effective dates should be different for various entities and just how many billable hours might be lost to figuring all of this out. So basically they need you guys to get on this ASAP because they’ve had several years to do it and are still lost.

The request is simple:

“Our joint workplan supporting the Memorandum of Understanding with the IASB identifies targeted completion dates for various projects, but does not address when the standards would be effective,” notes Acting FASB Chairman Leslie F. Seidman. “We issued this Discussion Paper to gather the information we need to create a realistic, cost-effective plan for transitioning to the new standards.”

In other words: can you guys ballpark the timeframe and how we’re going to pay for it? I’d rather see the profession spend its quality billable time writing comment letters on its opinion of the transition and/or FASB’s handling of it. I think you fringe accountants know what to do, so I thank you in advance.