On December 14, CCR filed its Lease comment letter with the FASB and IASB.  CCR continues to support the convergence of U.S. GAAP and IFRS and the project’s overall goal of improving the accounting for leases.  A lease provides a lessee use of an asset and contains an obligation to pay rent.  As a result, the proposed right-of-use accounting model that leads to the recognition by the lessee of the asset and liability is a natural consequence of this analysis and the evolution of the accounting model.  However, members continue to have concerns related to the complexity of the proposed model and the operability of a number of the proposed requirements.  The accounting for leases under current U.S. GAAP is often difficult to apply and rightly criticized for its complexity, including its mix of subjective judgments and “bright line” tests.  While the bright-line tests have been eliminated, the model presented in the ED imposes additional complexity, particularly related to estimating the lease term and in considering contingent rents.  Some of this resulting complexity is the consequence of an accounting model that does not completely consider the economics of many lease transactions or the conceptual framework.