FEI Comments On FASB's Fair Value Proposal
Sept. 1, 2010
FEI Summary

On Sept. 1, 2010 a joint comment letter was filed by FEI's Committee on Corporate Reporting and Committee on Corporate Treasury on the Financial Accounting Standards Board's proposal relating to financial instruments. Specifically, the comment letter was filed in response to FASB's Proposed Accounting Standards Update:  Financial Instruments (Topic 825) and Derivatives and Hedging (Topic 815) – Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. Note: technically, while the heading of the proposal addresses financial instruments, the key issue is the application of fair value, thus the heading at the top of this post.

FEI's 12-page comment letter, co-signed by CCR Chair Loretta Cangialosi and CCT Chair Susan Stalnecker, concluded that:

While we support the FASB and IASB convergence efforts, we are strongly opposed to many of the provisions included in the proposed ASU, including the pervasive expansion of the use of fair value, the inability to consider future events in the estimation of expected credit losses, and the overall lack of consistency between the proposal and an enterprise’s business strategy. The Proposed ASU will reduce the reliability of financial reporting and introduce significant operational complexity. Given these concerns and our belief that the expansion of fair value is not favored by the majority of financial statement users, we strongly encourage the FASB to delay the final issuance of the Proposed ASU until a single converged financial reporting model for financial instruments is developed.

Read further details in the FEI comment letter. A total of over 250 comment letters have been filed with FASB on this proposal to date.

Separately, Tom Selling, author of The Accounting Onion blog, has some things to say about this topic (and more) in his blog post today. Selling is the lead coordinator on a number of FASB-IASB-SEC-PCAOB courses offered by SmartPros/EEI.