"Collectively, we do not believe we have sufficient technical resources in industry to respond effectively to such a large quantity of complex proposals issued over a very short period of time. Even if it were not so, it is not clear to us that the FASB and IASB have the requisite resources to absorb and resolve all of the issues that would be posed by all of these proposed standards in such a compressed time period.

We also note that if we are not able to fully analyze and comment on these proposals, they could end up being finalized without the necessary analysis that our comments relative to real-life transactions, or with limited comments, leading to a large number of implementation issues and potentially significant amendments to the newly issued standards. We make these observations based on experiences with other major, complex standards, such as FIN 46 on Variable Interest Entities. Due to the very abbreviated time frame between issuance of the ED, issuance of the final standard and its effective date, the principles that were fundamental to operation of the standard needed to be amended through issuance of a revised standard (FIN 46R) and a series of subsequent FASB Staff Positions. If that were to occur with these standards, we do not think that type of process would be helpful to investors or preparers.

We note that a separate committee of FEI, FEI’s Committee on Private Companies-Standards, shares our concern and has filed a separate comment letter on this point."   [NOTE: See CPC-S letter to FASB.]

In conclusion, Hanish stated:

"We recommend that the FASB identify a representative group of preparers, auditors and financial statement users to identify logical groupings of revised standards and a timetable for the completion of each group that would avoid the types of issues we describe above. We would be pleased to provide representatives to serve on such a group."

Read more in the CCR letter.