The Financial Reporting Executive Committee, in conjunction with AICPA Expert Panels and task forces, has issued the following comment letters. Comment letters issued prior to 2019 can be requested by emailing Sharon Macey at Sharon.Macey@aicpa-cima.com

Letters to FASB

August 11, 2025 FinREC comment letter on FASB ITC Agenda Consultation

June 4, 2025 FinREC comment letter on FASB Intangibles ITC

May 5, 2025 FinREC Comment Letter on ITC Financial KPIs

February 3, 2025 FinREC - Proposed ASU-Software Comment Letter

October 23, 2024 FinREC comment letter on FASB’s Proposed Accounting Standards Update, Derivatives and Hedging (Topic 815) and Revenue from Contracts with Customers (Topic 606), Derivatives Scope Refinements and Scope Clarification for a Share-Based Payment from a Customer in a Revenue Contract

May 30, 2024 comment letter on the Financial Accounting Foundation’s Review of the Private Company Council

April 8, 2024 FinREC comment letter on FASB’s Proposed Statement of Financial Accounting Concepts, Concepts Statement No. 8, Conceptual Framework for Financial Reporting, Chapter 6: Measurement

Comment Letter dated December 4, 2023 on FASB’s Proposed Accounting Standards Update, “Income Statement—Reporting Comprehensive Income—Expense Disaggregation Disclosures (Subtopic 220-40) Disaggregation of Income Statement Expenses”

Comment Letter dated October 11, 2023 on FASB’s Proposed Accounting Standards Update, “Financial Instruments – Credit Losses (Topic 326)” (“ED”)

Comment Letter on June 5, 2023 FASB’s Proposed Accounting Standards Update, Intangibles—Goodwill and Other— Crypto Assets (Subtopic 350-60)– Accounting for and Disclosure of Crypto Assets

Comment Letter on May 31, 2023 FASB’s Proposed Accounting Standards Update, Income Taxes (Topic 740) Improvements to Income Tax Disclosures

Comment Letter on FASB’s Business Combinations— Joint Venture Formations

December 12, 2022 Comment Letter on FASB’s Proposed Accounting Standards Update, Segment Reporting (Topic 280) – Improvements to Reportable Segment Disclosures

September 21, 2022 FinREC Comment Letter on FASB's Invitation to Comment, Accounting for Government Grants by Business Entities

April 4, 2022 FinREC comment letter on FASB's Proposed Accounting Standards Update (ASU), “Liabilities – Supplier Finance Programs (Subtopic 405-50) – Disclosure of Supplier Finance Program Obligations.”

December 23, 2021 Finrec Comment Letter on FASB's Proposed ASU- Credit Losses - Troubled Debt Restructurings and Vintage Disclosures

September 17, 2021 FinREC's comment letter on FASB’s Invitation to Comment (ITC) Agenda Consultation

July 23, 2021 FinREC comment letter to FASB “Agenda Request - Clarification for Employee Benefit Plan Accounting”

March 22, 2021 FinREC comment letter to FASB on FASB Proposed Accounting Standards Update (ASU), “Business Combinations (Topic 805)–Accounting for Contract Assets and Contract Liabilities from Contracts with Customers.”

December 4, 2020 AICPA FinREC comment letter on the Financial Accounting Standards Board’s July 16, 2020, Exposure Draft—Concepts Statement No. 8, Conceptual Framework for Financial Reporting—Chapter 4: Elements of Financial Statements

August 6, 2020 - FinREC comment letter on the IASB’s December 2019 Exposure Draft: General Presentation and Disclosures (Primary Financial Statements).

March 9, 2020 - FinREC comment letter on Financial Accounting Standards Board’s February 10, 2020, Exposure Draft of a Proposed Accounting Standards Update—Not-for-Profit Entities (Topic 958): Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets.

October 19, 2019 - FinREC comment letter on FASB's July 31, 2019 Exposure Draft: Debt—Debt with Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging—Contracts in Entity’s Own Equity (Subtopic 815-40)

October 3, 2019 comment letter on FASB Invitation to Comment (ITC), “Identifiable Intangible Assets and Subsequent Accounting for Goodwill.”

July 15, 2019 - FinREC comment letter on FASB's May 14, 2019, Exposure Draft, Income Taxes (Topic 740)— Simplifying the Accounting for Income Taxes

June 7, 2019 Financial Accounting Standards Board’s (FASB or Board) March 25, 2019 Exposure Draft, Income Taxes (Topic 740)—Disclosure Framework—Changes to the Disclosure Requirements for Income Taxes.

February 1, 2019 comment letter on FASB's Dec. 2018 Exposure Draft of Proposed changes to Extending the Private Company Accounting Alternatives on Goodwill and Certain Identifiable Intangible Assets to Not-for-Profit Entities.

Letters to GASB

June 24, 2025 comment letter on GASB's Preliminary Views, Severe Financial Stress and Probable Dissolution Disclosures

February 18, 2025 comment letter on GASB's Exposure Draft, Subsequent Events

January 24, 2025 comment letter on GASB's Exposure Draft, Implementation Guidance Update

January 17, 2025 comment letter on GASB's Preliminary Views, Infrastructure Assets

December 21, 2023 comment letter on GASB’s Exposure Draft on Disclosure and Classification of Certain Capital Assets

February 17, 2023 comment letter on GASB's Exposure Draft, Additional Proposal for Implementation Guidance Update—2023

January 20, 2023, comment letter on GASB’s Exposure Draft, Implementation Guidance Update—2023

September 29, 2022 comment letter on GASB’s Exposure Draft, Certain Risk Disclosures

September 14, 2021 comment letter on GASB's Revised Exposure Draft, Communication Methods in General Purpose External Financial Reports That Contain Basic Financial Statements: Notes to Financial Statements

September 14, 2021 comment letter on GASB's Exposure Draft, Omnibus 20XX

August 24, 2021 comment letter on GASB'S Exposure Draft, Accounting Changes and Error Corrections

June 23, 2021 comment letter on GASB’s Exposure Draft, The Annual Comprehensive Report

February 26, 2021 comment letter on GASB's Exposure Drafts, Financial Reporting Model Improvements and Recognition of Elements of Financial Statements