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: SEC comment letters

Date Issued

Headline

08/03/2011

SEC’s Work Plan for the Consideration of Incorporating International Financial Reporting Standards

01/31/2011

SEC’s detailed XBRL tagging requirement

10/18/2010

SEC IFRS Work Plan Incorporation Implication

10/18/2010

CCR comments on the SEC IFRS Work Plan Investor Education

07/02/2010

CCR’s letter to the SEC addressing concerns with time needed for detailed footnote tagging required.

06/24/2009

FEI Comments On Credit Rating Agencies

04/20/2009

FEI Comments On SEC's Proposed IFRS Roadmap

01/23/2009

FEI Asks SEC To Extend Comment Period On Proposed IFRS Roadmap

08/04/2008

FEI's CCR and CFIT Committees Provide Views on SEC's XBRL Letter

04/04/2008

CCR Comment Letter on SEC CiFIR Progress Report

04/02/2008

FEI's Technical Committees (CFIT) and (CSMPC) respond to the CIFiR’s interim recommendations.

11/15/2007

CCR Comments to SEC on IFRS Concept Release

09/26/2007

CCR responds to SEC Advisory Committee on Improvements to Financial Reporting

09/25/2007

Foreign Private Issuers Financial Statements in IFRS without Reconciliation to U.S. GAAP

07/18/2007

FEI Small Public Company Task Force Responds to SEC Proposal

03/15/2007

FEI Committee Weighs In On Credit Rating Agency Rulemaking

02/26/2007

FEI Comments To SEC, PCAOB On Sarbanes-Oxley Section 404

09/19/2006

FEI Responds To SEC Concept Release On Internal Control

09/13/2006

FEI Small Public Co. Task Force Comments Re Proposed 404 Delay

05/01/2006

FEI's CCR Provides Feedback on Year Two Internal Control Reporting

04/24/2006

FEI Comments On Proposed Executive Comp Regulations

04/04/2006

FEI Small Public Company Task Force Comments to SEC on Advisory Committee Recommendations

1/5/2006

FEI’s CCR, IMA Comment To SEC On Customer Relationship Intangibles

10/31/2005

FEI Small Public Company Task Force (SPCTF) submits comment letter to the SEC

08/31/2005

FEI Small Public Company Task Force Comment Letter to SEC

07/20/2005

CCR provides feedback to SEC requesting the SEC maintain the temporary postponement of the final phase-in of accelerated filing dates for Form 10-Q.

04/1/2005

CCR provides feedback regarding the implementation of Section 404 (“Section 404”) of the Sarbanes-Oxley Act (the “Act”) relating to internal control over financial reporting.

04/30/2004

CCR responds to SEC on PCAOB AS2.

09/30/2003

FEI/IMA additional comments on FR-67 The Committee on Corporate Reporting and the Financial Reporting Committee of the Institute of Management Accountants provide comments to the SEC on significant issues that have arisen regarding certain requirements of FR-67, Disclosure in MD&A about Off-Balance Sheet Arrangements and Aggregate Contractual Obligations.

3/12/2003

FEI's CCR provides additional comments on Section 404, on internal control attestations; the role of the PCAOB in audit standard setting.

2/19/2003

CCR responds to the SEC Proposed Rule on Standards Relating to Listed Company Audit Committees, providing input on the areas of auditor responsibilities, complaint procedures, other advisors and funding.

1/14/2003

CCR responds to SEC Proposed Rule on Amendments to Auditor Independence encouraging improved standards, but citing issues with proposals related to tax services and auditor rotation among others.

1/2/2003

CCR comments on the SEC's proposed rule to enhance MD&A disclosure of off-balance sheet arrangements, supporting the initiative but expressing concern for decreased thresholds for requiring disclosure.

12/16/2002

CCR responds to the SEC's proposal on use of pro forma information in Financial Reporting

12/2/2002

CCR responds to SEC rule proposal on Internal Control Reports, Financial Experts, and Codes of Ethics.

8/21/2002

CCR comments on the SEC proposed rule on 8-K Disclosure Requirements and Acceleration of Filing Date supporting the proposal in principal, but strongly advocating revisions in certain areas.

7/18/2002

CCR supports the principles behind the SEC proposed rule on MD&A Disclosure of Critical Accounting Policies, but expresses concern with regard to the definition of critical estimates and the detailed level of disclosures required.

6/27/2002

CCR Supports the SEC Decision to Establish the framework for a Public Accountability Board

5/21/2002

FEI responds to the SEC proposal for accelerated filings of Forms 10Q and 10K , supporting the SEC efforts while addressing concerns over shortened 10Q filings.

1/16/2002

CCR supports the SEC proposal to Mandate Edgar filings for Foreign Issuers, agreeing that its adoption would contribute to accomplishing the long-standing goals of the EDGAR system that being to facilitate the rapid dissemination of financial and business information while making the delivery and processing of the Commission’s filings more efficient.

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