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FASB-IASB Financial Crisis Advisory Group Seeks Comment By April 2

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FASB-IASB Financial Crisis Advisory Group Seeks Comment By April 2
March 11, 2009
FEI Summary

The Financial Crisis Advisory Group, a high-level advisory group formed by the Financial Accounting Standards Board and the International Accounting Standard Board late last year, issued a request for comment on March 9, 2009 on various matters. The questions on which FCAG seeks comments are:

  1. From your perspective, where has general purpose financial reporting helped identify issues of concern during the financial crisis? Where has it not helped or even possibly created unnecessary concerns? Please be as specific as possible in your answers.

  2. If prudential regulators were to require "through-the-cycle" or "dynamic" loan provisions that differ from the current IFRS [International Financial Reporting Standards] or US GAAP [U.S. generally accepted accounting principles) requirements, how should general purpose financial statements best reflect the difference: 1) recognition in profit or loss (earnings); 2) recognition in other comprehensive income; 3) appropriation of equity outside of comprehensive income; 4) footnote disclosure only; 5) some other means; or 6) not at all? Please explain how your answer would promote transparency for investors and other resource providers.

  3. Some FCAG members have indicated that they believe issues surrounding accounting for off-balance items such as securitizations and other structured entities have been far more contributory to the financial crisis than issues surrounding fair-value (including mark-to-market) accounting. Do you agree, and how can we best improve IFRS and US GAAP in that area?

  4. Most constituents agree that the current mixed-attributes model for accounting and reporting of financial instruments under IFRS and US GAAP is overly complex and otherwise suboptimal. Some constituents (mainly investors) support reporting all financial instruments at fair value. Others support a refined mixed attributes model. Which approach do you support and why? If you support a refined mixed attributes model, what should that look like, and why, and do you view that as an interim step toward full fair value or as an end goal? Whichever approach you support, what improvements, if any, to fair value accounting do you believe are essential prerequisites to your end goal?

  5. What criteria should accounting standard-setters consider in balancing the need for resolving an "emergency issue" on a timely basis and the need for active engagement from constituents through due process to help ensure high quality standards that are broadly accepted?

  6. Are there financial crisis-related issues that the IASB or the FASB have indicated they will be addressing that you believe are better addressed in combination with, or alternatively by, other organizations? If so, which issues and why, and which organizations?

  7. Is there any other input that you'd like to convey to the FCAG?

FCAG's comment deadline is April 2 - which coincidentally is the date of the next meeting of the Group of Twenty Finance Ministers and Central Bank Governors (G-20). Further information about the G-20 is available at www.g20.org .

Resources:

FCAG March 5, 2009 meeting: BNA article 1 of 2, by Steve Burkholder (Copyright BNA, used with permission)

FCAG March 5, 2009 meeting: BNA article 2 of 2, by Steve Burkholder (Copyright BNA, used with permission)

FCAG Feb. 13, 2009 meeting: FEI summary 

Prepared March 11, 2009 by Edith Orenstein, Director, Accounting Policy Analysis, Financial Executives International (FEI). This summary does not reflect FEI opinion unless specifically noted above.

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