September 29,2010. Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
|
|
- Gladys Haynes
- 5 years ago
- Views:
Transcription
1 Starbucks Coffee Company PO Box Seattle, WA / September 29,2010 Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT File Reference No Dear Mr. Golden: Starbucks Corporation appreciates the opportunity to comment on the FASB' s proposed Accounting Standards Update Accounting for Financial Instruments and Revisions to the Accountingfor Derivative Instruments and Hedging Activities (the "proposed ASU"). We welcome the opportunity to provide input into the standard setting process in this important area and we support global convergence for high-quality accounting standards. Accordingly, we commend the Board on its continued efforts to work closely with the International Accounting Standards Board (IASB) and other national standard setters to develop high-quality standards that will be applied globally. However, we do not support the issuance of the proposed ASU as a final standard. The remainder of this letter provides our views on several key areas of the proposed ASU which include the classification and measurement of equity investments that are currently accounted for under the cost method and certain proposals related to the accounting for derivatives and hedges. Classification and Measurement of Equity Investments We do not agree with the underlying premise in the proposed ASU that all equity instruments not accounted for under the equity method of accounting (as proposed to be limited) should be measured at fair value, with the changes in fair value recognized in net income. We are concerned that the proposed ASU will inappropriately eliminate the current use of the cost method of accounting for certain non-marketable equity investments. Our strong preference is for the FASB and IASB to develop a converged approach for the application of the equity method and the cost method of accounting for non-marketable equity securities, outside of this proposed ASU.
2 Page 2 However, ifthe proposed changes to the equity method of accounting are made, we believe a similar approach should be followed for non-marketable equity investments currently accounted for under the cost method. That is, for non-marketable equity investments for which the investor does not exert significant control, but for which the operations of the investee are considered related to the investor's consolidated operations, we believe it would be appropriate to continue to account for these investments under the cost method. We believe this would be applicable in circumstances where the equity investee'sbusiness purpose relates to the investor's uriderlying business and the operations and related cash flows of the operating entity are paramount, rather than the fair value of the investment itself. For all other equity investments (marketable and non-marketable), we do agree that fair value is the most appropriate measurement method, with changes in fair value reported in net income. As background, Starbucks has several non-marketable equity investments in entities that develop and operate Starbucks licensed retail stores. Our overall store operations portfolio includes both company-operated stores and licensed stores. For our licensed store operations, we have varying levels of equity ownership in the operations of our licensed store partners. In some cases we have no equity ownership, in some cases an equity ownership of less than 20%, and in many cases, equity ownership of 50%. In each of these licensed store arrangements, our fundamental business operation is the licensed store operation itself and the related royalty, license fees and product sales they generate for us. These cash flows represent the underlying economics of the operations and are how management evaluates the operations. In every case, the licensed store business model is to operate profitable stores that generate ongoing cash flows for Starbucks, and not to manage. the related non-marketable equity investment as a financial instrument on a fair value basis. Further, we do not measure fair value for our non-marketable equity investments in these entities (except for any impairment analysis that may be required), do not provide incentives to either Starbucks employees or license partners on this basis, and do not seek monetizing events, including sales, of these non-marketable equity investments. We expect that users of our financial statements would find mark-to-market adjustments in income related to these investments to be non-operational, and would not consider them useful for predicting future cash flows. As a result, we believe these mark-to-market adjustments would skew the true results of our operations and would limit an investor's ability to understand the economics of the ownership arrangement.
3 Page 3 We recommend that for certain non-marketable equity investments, an approach similar to that in the proposed ASU for equity method investments be provided for cost method investments. That is, for non-marketable equity investments for which the operations of the investee are related to the investor's consolidated operations and for which the business strategy is generating cash flows from the ongoing operations of the investment rather than realizing fair value changes, continued use of the cost method of accounting should be allowed. Factors to be considered in evaluating whether the operations of the investee are considered related to the investor's consolidated operations would be the same as those related to equity method investments as discussed in paragraph 130 of the proposed ASU. Accounting for Derivatives and Hedging Bifurcation-by-risk of Nonfinancial Risk Components Under ASC 815, the risk being hedged must be for the entire hedged item in a fair value hedge or the entire asset to be acquired or sold in a hedged forecasted transaction, to receive hedge accounting treatment. As a result, many nonfinancial companies that are faced with significant exposures to market risks created through the ordinary course of business have been unable to successfully qualify for hedge accounting. The rationale provided in ASC 815 is that "changes in the price of an ingredient or component of a nonfinancial item do not have a predictable, separately measurable effect on the price of an item." We do not believe the premise for this argument is correct. In fact, for certain nonfinancial assets there are explicit pricing features that lead to predictable, separately identifiable, and measurable effects on the total price of the item. We also note that during its February 2,2010 meeting the IASB tentatively agreed to permit the bifurcation-by-risk. for financial items, with a leaning toward also permitting bifurcation-by-risk for nonfinancial items. We strongly encourage the Board to integrate the IASB' s position into the final Financial Instruments Accounting Standards Update. An example of a specific non-fmancial risk item is fluid milk. Most procurement contracts between Starbucks and its dairy suppliers explicitly reference the Base Skim Price for Class I milk (published monthly by the United States Department of Agriculture) to determine the total price paid to the supplier. This risk component is separately identifiable, measurable, and has a predicted effect on the total price of milk. Because we are unable to bifurcate that specific commodity risk component, and must instead assess and measure effectiveness against all other risk components (such as fuel costs related to store delivery), we are not able to meet the criteria for a highly effective hedge. Despite the inability to receive hedge accounting treatment, Starbucks hedges some of this risk
4 Page 4 from an economic perspective as a matter of prudent risk management. This results in changes in reported earnings that don't reflect the underlying economics due to the timing difference of earnings recognition between the cash flows of the underlying exposure and the hedging instrument. Although the Board's proposal of shifting the standard from "highly effective" to "reasonably effective" is a move in the right direction, we believe bifurcation-by-risk of nonfinancial risk components is the proper solution. Dedesignation We believe the proposed change to prohibit the voluntary dedesignation of a hedging relationship will add unnecessary complexity for financial statement preparers, does not provide materially improved financial information for users, and thus does not pass the cost-benefit trade off test. As background, Starbucks hedges certain forecasted foreign currency payments using forward agreements. Because the exact timing of cash flows is not known at the onset of the hedge, we track the transactions and dedesignate the hedging relationship once the forecasted payment becomes a payable. From that point until the settlement date, the derivative will be marked-to-market. Correspondingly, the payable will be marked to the then current spot rate. This approach would be prohibited under the proposed ASU. Instead, we would either have to enter into additional transactions to replicate this practice or undertake a more complicated accounting method outlined in through 112 (Example 18). Both choices increase complexity, administrative burden and/or transaction costs without providing a more representative view to the financial statement user of the derivatives being utilized. Elimination of the Critical Terms Match Method While the elimination of the critical terms match method might remove some concern by financial statement users that the methodology is being unintentionally misapplied, we believe the measurement of ineffectiveness in such cases would unnecessarily increase the administrative burden for financial statement preparers. Many foreign currency cash flow exposures can be hedged using the critical terms match method such that any ineffectiveness is insignificant. In these cases the quantitative measurement of ineffectiveness (as currently described) would not improve the representation of the economics or cash flows of the hedging relationship, but instead would add unnecessary complexity and administrative burden.
5 Page 5 Hedge Effectiveness Measurement for Cash Flow Hedges The proposed guidance in the ASU requires that, when accounting for cash flow hedges, ineffectiveness for "underhedges" be recognized in net income, in addition to "overhedges". If the cumulative change in fair value of the hedged item is less than the change in fair value of the hypothetical (i.e., "perfect") derivative, the resulting ineffectiveness recognized into earnings would be a result of gains or losses that will never exist. This would add artificial volatility to earnings and not fairly represent the underlying economics of the hedging relationship. Thus, we believe that no ineffectiveness should be recognized into earnings related to an underhedge situation. Again, we thank the FASB for the opportunity to comment on the proposed ASU and would be pleased to discuss our comments in greater detail if that would be helpful. Sincerely, Donna Brooks Vice President and Controller
September 1, Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
Deloitte & Touche LLP Ten Westport Road PO Box 820 Wilton, CT 06897-0820 Tel: +1 203 761 3000 Fax: +1 203 834 2200 www.deloitte.com Mr. Russell G. Golden Technical Director Financial Accounting Standards
More informationFile Reference No Re: Proposed Statement, Accounting for Hedging Activities an amendment of FASB Statement No. 133
Deloitte & Touche LLP Ten Westport Road PO Box 820 Wilton, CT 06897-0820 USA Tel: +1 203 761 3000 Fax: +1 203 834 2200 www.deloitte.com August 15, 2008 Mr. Russell G. Golden Technical Director Financial
More informationNovember 29, Russell G. Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
November 29, 2016 Russell G. Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 File Reference No. 2016-310 Submitted via electronic mail to director@fasb.org
More informationFile Reference: No Selected Issues about Hedge Accounting (Including IASB Exposure Draft, Hedge Accounting)
Louis Rauchenberger Managing Director & Corporate Controller April 25, 2011 Susan M. Cosper Financial Accounting Standards Board 401 Merritt 7, Norwalk, CT 06856-5116 File Reference: No. 2011-175 Selected
More information10 September Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5166 Norwalk, CT
e Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: 212 773 3000 www.ey.com 1810-100 Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5166 Norwalk,
More informationFASB Projects Update Spring 2015
FASB Projects Update Spring 2015 Presentation to the American Petroleum Institute March 31, 2015 Mark Pollock, Practice Fellow This presentation has been prepared to help stakeholders understand the current
More informationNovember 4, Ms. Susan Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7, P.O. Box 5116 Norwalk, CT
November 4, 2016 Ms. Susan Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7, P.O. Box 5116 Norwalk, CT 06856-5116 RE: File Reference No. 2016-310 Dear Ms. Cosper: PricewaterhouseCoopers
More informationSeptember 9, 2010 Technical Director Financial Accounting Standards Board 401 Merritt 7 Norwalk, CT File Reference: No.
September 9, 2010 Technical Director Financial Accounting Standards Board 401 Merritt 7 Norwalk, CT 06856-5116 File Reference: No. 1830-100 Dear Mr. Golden: The Financial Reporting Executive Committee
More informationSeptember 30, Technical Director Financial Accounting Standards Board 401 Merritt 7, P.O. Box 5116 Norwalk, CT
100 Constellation Way, Suite 600C Baltimore, Maryland 21202 6302 410.234.5000 www.constellation.com September 30, 2010 Technical Director Financial Accounting Standards Board 401 Merritt 7, P.O. Box 5116
More informationInterpretation 48-Delay of Effective Date for Nonpublic Entities and Guidance for Pass-Through Entities
Interpretation 48-Delay of Effective Date for Nonpublic Entities and Guidance for Pass-Through Entities BACKGROUND Board Meeting Handout November 7, 2007 FASB Interpretation No. 48, Accounting for Uncertainty
More informationFile Reference
Institutional Limited Partners Association s Response to the Financial Accounting Standards Board s Proposed Accounting Standards Update Fair Value Measurements and Disclosures (Topic 820) 1 September
More informationNovember 4, Susan M. Cosper Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT Via to
November 4, 2016 Susan M. Cosper Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Via Email to director@fasb.org Grant Thornton Tower 171 N. Clark Street, Suite 200 Chicago, IL
More information28 September Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, Connecticut
28 September 2010 Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, Connecticut 06856-5116 Dear Mr Golden Proposed Accounting Standards Update
More informationFile Reference No Re: Proposed Accounting Standards Update, Simplifying the Equity Method of Accounting
695 East Main Street P.O. Box 10098 Stamford, CT 06901-2150 Tel: + 1 203 761 3000 www.deloitte.com Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116
More informationWe support a mixed attribute model for financial instruments over the fair-value-foralmost-all-financial-instruments
September 30, 2010 Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, Connecticut 06856-5116 Re: File Reference No. 1810-100; Exposure Draft
More informationTel: ey.com
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director File Reference No. 2016-310 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationThe attached appendix responds to the Board s questions and offers our additional suggestions for the Board s consideration.
Technical Director 401 Merritt 7 P.O. Box 5116 Norwalk, Connecticut 06856-5116 The AICPA s Financial Reporting Executive Committee (FinREC) appreciates the opportunity to comment on the Proposed Accounting
More informationAugust 17, Via to
August 17, 2015 Via email to director@fasb.org Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Re: File Reference No. 2015-230
More information~ Merrill Lynch. David Moser Managing Director. Merrill Lynch & Co., Inc. Accounting Policy and Corporate Reporting
~ Merrill Lynch David Moser Managing Director Merrill Lynch & Co., Inc. Accounting Policy and Corporate Reporting 4 World Financial Center, FI15 New York, NY 10080 Tel: (212) 449-2048 Fax: (212) 449-0970
More informationDear Mr. Golden, Key Messages:
Deutsche Bank AG London Winchester House 1 Great Winchester Street London EC2N 2DB Tel. +44 20 7545 8000 Mr. Russell Golden, Technical Director 7 September 2010 File Reference No. 1830-100, Financial Accounting
More informationTechnical Line FASB proposed guidance
No. 2016-27 20 December 2016 Technical Line FASB proposed guidance A closer look at the FASB s hedge accounting proposal In this issue: Overview... 1 Key provisions of the proposal... 2 Background... 4
More informationACCOUNTING FOR FINANCIAL INSTRUMENTS AND REVISIONS TO THE ACCOUNTING FOR DERIVATIVE INSTRUMENTS AND HEDGING ACTIVITIES
30 September 2010 Our ref: ICAEW Rep 101/10 Your ref: 1810-100 Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk Connecticut 06856-5116 USA Dear Sir / Madam ACCOUNTING
More informationTechnical Corrections and Improvements to Financial Instruments Overall (Subtopic ) No February 2018
No. 2018-03 February 2018 Technical Corrections and Improvements to Financial Instruments Overall (Subtopic 825-10) Recognition and Measurement of Financial Assets and Financial Liabilities An Amendment
More informationFASB Proposes Targeted Improvements to Hedge Accounting Relief Is Coming. Heads Up September 14, 2016 Volume 23, Issue 25. In This Issue.
Heads Up September 14, 2016 Volume 23, Issue 25 In This Issue Introduction Key Proposed Changes to the Hedge Accounting Model Transition and Adoption Comparison With IFRSs Appendix A Questions for Respondents
More informationProposed Accounting Standards Update, Intra-Entity Asset Transfers (File Reference No )
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116
More informationFebruary 14, 2012 Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
February 14, 2012 Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 File Reference No. 2011-200 Dear Ms. Cosper: The Financial Reporting Executive
More informationRE: Exposure Draft, Compensation Stock Compensation (Topic 718): Improvements to Employee Share-Based Payment Accounting (File Reference No.
KPMG LLP Telephone +1 212 758 9700 345 Park Avenue Fax +1 212 758 9819 New York N.Y. 10154-0102 Internet www.us.kpmg.com August 14 2015 Technical Director Financial Accounting Standards Board 401 Merritt
More informationTel: ey.com
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director File Reference No. 2018-220 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationOctober 5, File References: EITF-15D and EITF-15E Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
File References: EITF-15D and 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Dear Ms. Cosper: File References: EITF 15-D Derivatives and Hedging (Topic 815) Effect of Derivative Contract Novations
More informationFile Reference No I, Intra-Entity Asset Transfers, and File Reference No II, Balance Sheet Classification of Deferred Taxes
Eli Lilly and Company Lilly Corporate Center Indianapolis, Indiana 46285 U.S.A. May 27, 2015 Technical Director Financial Accounting Standards Board 401 Merritt 7, P.O. Box 5116 Norwalk, CT 06856-5116
More informationFebruary 29, Via Electronic Mail
February 29, 2016 Via Electronic Mail Mr. Russ Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-05116 Re: FASB File Reference No. 2015-350: Fair Value
More informationSir David Tweedie International Accounting Standards Board 30 Cannon Street London EC4M 6XH. 9 March Dear Sir David
Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ Tel: +44 (0) 20 7936 3000 Fax: +44 (0) 20 7583 1198 www.deloitte.com Sir David Tweedie International Accounting Standards Board 30 Cannon
More informationRevenue from Contracts with Customers (Topic 606)
No. 2015-14 August 2015 Revenue from Contracts with Customers (Topic 606) Deferral of the Effective Date An Amendment of the FASB Accounting Standards Codification The FASB Accounting Standards Codification
More informationTIC has reviewed the ED and is providing the following comments for your consideration. GENERAL COMMENTS
December 9, 2015 Susan M. Cosper, CPA Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT 06856 5116 Re: September 24, 2015 Exposure Draft of a Proposed Accounting Standards Update (ASU), Notes
More informationKPMG LLP 757 Third Avenue New York, NY 10017
KPMG LLP 757 Third Avenue New York, NY 10017 Telephone 212-909-5600 Fax 212-909-5699 Internet www.us.kpmg.com File Reference No. 1720-100 (FASB) 401 Merritt 7 PO Box 5116 Norwalk, Connecticut 06856-5116
More informationProposed Accounting Standards Update, Business Combinations (Topic 805): Clarifying the Definition of a Business (File Reference No.
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director File Reference No. 2015-330 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationDecember 16, Mr. Russell Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
December 16, 2016 Mr. Russell Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-05116 Re: Proposed Exposure Draft, Derivatives and Hedging (Topic 815) Dear
More informationDear Chairman Gruenberg, Chair Yellen, Comptroller Otting, and Chairman Clayton, Tax Reform Affects Long Term Bank Management and Asset Quality
Michael L. Gulllette Senior Vice President Tax and Accounting 0-66-4986 January, 018 The Honorable Martin J. Gruenberg Chairman Federal Deposit Insurance Corporation 550 17th Street, N.W. Washington, D.C.
More informationTechnical Line FASB final guidance
No. 2018-04 Updated 4 October 2018 Technical Line FASB final guidance A closer look at the FASB s new hedge accounting standard Revised 4 October 2018 In this issue: Overview... 1 Key provisions of the
More informationDecember 19, Mr. Russell G. Golden Chairman Financial Accounting Standards Board 401 Merritt 7 Norwalk, CT
Deloitte & Touche LLP Ten Westport Road P.O. Box 820 Wilton, CT 06897-0820 Tel: +1 203 761 3000 Fax: +1 203 834 2200 www.deloitte.com December 19, 2013 Mr. Russell G. Golden Chairman Financial Accounting
More informationDeloitte & Touche LLP
695 East Main Street Stamford, CT 06901-2141 Tel: + 1 203 708 4000 Fax: + 1 203 708 4797 www.deloitte.com Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationCENTER FOR CAPITAL MARKETS COMPETITIVENESS
CENTER FOR CAPITAL MARKETS COMPETITIVENESS RicIijuD H. Muiu 1615 H STREET, NW WASHINGTON, DC 20062-2000 (212) 317-5339 Richard Murray@swissre.com Mr. Russell G. Golden FASB Technical Director Financial
More informationRe: Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9
16 April 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir/Madam, Re: Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9 On
More informationRe: FASB Preliminary Views, Financial Instruments with Characteristics of Equity
May 23, 2008 Mr. Robert Herz Chairman Financial Accounting Standards Board 401 Merritt 7 Norwalk, CT 06856 Re: FASB Preliminary Views, Financial Instruments with Characteristics of Equity Dear Mr. Herz:
More informationLEDER OF COMMENT NO. April I, 2009
William Killmer Executive Vice President Advocacy LEDER OF COMMENT NO. April I, 2009 Mr. Russell Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116
More informationDerivatives and Hedging (Topic 815)
Proposed Accounting Standards Update Issued: February 24, 2015 Comments Due: April 30, 2015 Derivatives and Hedging (Topic 815) Disclosures about Hybrid Financial Instruments with Bifurcated Embedded Derivatives
More informationPNC. February 15, Ms. Susan Cosper Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
PNC February 15, 2012 Ms. Susan Cosper Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-05116 Re: File Reference No., Proposed Accounting Standards Update, Financial Services
More informationA Deep Dive into Hedging
Table of Contents INTRODUCTION... 4 CURRENT HEDGE ACCOUNTING GUIDANCE... 4 COMMON HEDGING STRATEGIES... 5 RISK COMPONENT HEDGING... 6 CASH FLOW HEDGE... 6 Nonfinancial Asset... 6 Financial Asset... 7 FAIR
More informationTIC has reviewed the ED and is providing the following comments for your consideration. GENERAL COMMENTS
August 15, 2008 Russell G. Golden, CPA Technical Director FASB 401 Merritt 7 POBox 5116 Norwalk, CT 06856-5116 IIII~III~ 11111 o - 1 00.. LEDER OF COMMENT NO. 7K Re: June 6, 2008 Exposure Draft (ED) of
More informationJuly 8, Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
Deloitte & Touche LLP Ten Westport Road PO Box 820 Wilton, CT 06897-0820 Tel: +1 203 761 3000 Fax: +1 203 834 2200 www.deloitte.com Mr. Russell G. Golden Technical Director Financial Accounting Standards
More informationStatement 133 Implementation Issue. Notice for Recipients of This Proposed Statement 133 Implementation Issue
Notice for Recipients of This Proposed Statement 133 Implementation Issue This proposed Implementation Issue would amend the accounting and reporting requirements of paragraph 68 of Statement 133 (the
More informationFile Reference: No Proposed ASU, Derivatives and Hedging, Scope Exception Related to Embedded Credit Derivatives
PricewaterhouseCoopers LLP 400 Campus Dr. Florham Park NJ 07932 Telephone (973) 236 4000 Facsimile (973) 236 5000 www.pwc.com November 12, 2009 Russell G. Golden Technical Director Financial Accounting
More informationRe: Research Project, Distinguishing Liabilities from Equity
July 21, 2017 Russell G Golden, Chairman Susan M Cosper, Technical Director FASB 401 Meritt 7 PO Box 5116 Norwalk, CT 06856-5116 Grant Thornton Tower 171 N. Clark Street, Suite 200 Chicago, IL 60601-3370
More informationTHE CLEARING HOUSE", HOUSE, Advancing Payme-nt Payment Solutions Worldwide
1 6 Z O - 1 O O * LETTER OF COMMENT NO 3) NO. b THE CLEARING HOUSE", HOUSE, Advancing Payme-nt Payment Solutions Worldwide Norman R. Nelson General Counsel 450 West 33'" Street New York, NY 10001 tele
More informationISDA. October 15, 2007
ISDA International Swaps and Derivatives Association, Inc. 360 Madison Avenue, 16th Floor New York, NY 10017 United States of America Telephone: 1 (212) 901-6000 Facsimile: 1 (212) 901-6001 email: isda@isda.org
More informationVia August 24, 2009
Via email: director@fasb.org August 24, 2009 Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Re: Proposed Statement of Financial
More informationStatement of Financial Accounting Standards No. 101
Statement of Financial Accounting Standards No. 101 FAS101 Status Page FAS101 Summary Regulated Enterprises Accounting for the Discontinuation of Application of FASB Statement No. 71 December 1988 Financial
More informationFair value measurement
Financial reporting developments A comprehensive guide Fair value measurement Revised October 2017 To our clients and other friends Fair value measurements and disclosures continue to be topics of interest
More informationEliminating the Accounting for Basis Differences in Equity Method Investments
KPMG LLP Telephone +1 212 758 9700 345 Park Avenue Fax +1 212 758 9819 New York, N.Y. 10154-0102 Internet www.us.kpmg.com July 30, 2015 Technical Director Financial Accounting Standards Board 401 Merritt
More information1000 Stanley Drive New Britain. CT RE: File Reference No : Accounting for Hedging Activities, an amendment of F ASB Statement No.
The Stanlev Works 1000 Stanley Drive New Britain. CT 06053 Tel 86D-225-5111 STANLEY, August 14,2008 Technical Director - File Reference No. 1590-100 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationMarch 20, Ms. Leslie Seidman Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
March 20, 2012 Ms. Leslie Seidman Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-05116 Chairman International Accounting Standards Board 30 Cannon Street London
More informationFebruary 15, Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
2011-200 Deloitte & Touche LLP 10 Westport Road P.O. Box 820 Wilton, CT 06897-0820 USA Tel: +1 203 761 3000 Fax: +1 203 834 2200 www.deloitte.com Ms. Susan M. Cosper Technical Director Financial Accounting
More informationFinancial Instruments Overall (Subtopic )
Proposed Accounting Standards Update Issued: February 14, 2013 Comments Due: May 15, 2013 Financial Instruments Overall (Subtopic 825-10) Recognition and Measurement of Financial Assets and Financial Liabilities
More informationDeloitte & Touche LLP
695 East Main Street Stamford, CT 06901-2141 Tel: +1 203 708 4000 Fax: +1 203 708 4797 www.deloitte.com Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box
More informationEquity Interests an amendment of GASB Statement No. 14, and are pleased to offer our
Mr. David R. Bean Director of Research and Technical Activities Project No. 36 Governmental Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Dear Mr. Bean: Members of the American
More informationTel: ey.com
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director File Reference No. 2017-220 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationIAS 39, Financial Instruments: Recognition and Measurement. 3. IASB Exposure Draft, Hedge Accounting. 4
October 16, 2012 Volume 19, Issue 27 Heads Up In This Issue: Background Hedging Instruments Hedged Items Qualifying Criteria for Applying Hedge Accounting Accounting for Qualifying Hedges Modifying and
More informationProposed FASB Staff Position No 46-e, Effective Date offasb Interpretation No. 46, Consolidation of Variable Interest Entities
FSPFIN 46-e COORS BREWING COMPANY October 6, 2003 Mr. Lawrence W. Smith Director of Technical Application and Implementation Activities Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116
More informationTel: ey.com
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director File Reference No. 2016-370 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationProposed Accounting Standards Update, Leases (Topic 842) Targeted Improvements (File Reference No )
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director File Reference No. 2018-200 Financial Accounting Standards Board 401 Merritt 7 P.O.
More informationMs. Susan Cosper Technical Director, Financial Accounting Standards Board Chairwoman, Emerging Issues Task Force
May 18, 2015 Mr. Russell Golden Chairman, Financial Accounting Standards Board Ms. Susan Cosper Technical Director, Financial Accounting Standards Board Chairwoman, Emerging Issues Task Force 401 Merritt
More informationApril 1, Mr. Russell Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
April 1, 2014 Mr. Russell Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-05116 Re: File Reference No. 2013-220: Financial Instruments - Overall (Subtopic
More informationMs. Susan Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
Ms. Susan Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 April 25, 2016 RE: File Reference No. 2016-200 Dear Ms. Cosper, PricewaterhouseCoopers
More informationAugust 29, Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, Connecticut
Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, Connecticut 06856-5116 File Reference No. PCC-13-03; Comment Deadline: August 23, 2013 The Financial Reporting
More informationDiscontinued operations
Financial reporting developments A comprehensive guide Discontinued operations Accounting Standards Codification 205-20 (prior to the adoption of ASU 2014-08, Reporting Discontinued Operations and Disclosure
More informationSeptember 30, Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT
September 30, 2010 Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Re: File Reference No. 1810-100 - Proposed Accounting Standards Update, Accounting
More informationRe: Comments on ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9
China Accounting Standards Committee April 11, 2012 Mr. Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London, EC4M 6XH United Kingdom Dear Mr. Hans Hoogervorst, Re:
More informationMay 5, Susan M. Cosper, CPA Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT
May 5, 2017 Susan M. Cosper, CPA Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Re: FASB January 10, 2017 Proposed Accounting Standards Update Debt (Topic 470) Simplifying the
More informationHeads Up. IASB Issues IFRS on Classification and Measurement of Financial Assets.
vember 17, 2009 Volume 16, Issue 42 Heads Up In This Issue: Introduction Scope Classification Classification Criteria Equity Investments Embedded Derivatives Application Issues Reclassification Impact
More informationIntangibles Goodwill and Other (Topic 350) Business Combinations (Topic 805) Consolidation (Topic 810) Derivatives and Hedging (Topic 815)
No. 2016-03 March 2016 Intangibles Goodwill and Other (Topic 350) Business Combinations (Topic 805) Consolidation (Topic 810) Derivatives and Hedging (Topic 815) Effective Date and Transition Guidance
More informationQuarterly Accounting Update: On the Horizon The following selected FASB exposure drafts and projects are outstanding as of April 12, 2015.
Quarterly Accounting Update: On the Horizon The following selected FASB exposure drafts and projects are outstanding as of April 12, 2015. Proposed Delay of Effective Date for Revenue Recognition Standard
More informationMay 31, Re: FASB Financial Instruments Credit Losses (Subtopic ); IASB ED/2013/3 Financial Instruments Expected Credit Losses.
Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Chairman International Accounting Standards Board 30 Cannon Street London, EC4M 6XH United Kingdom Re: FASB
More informationJoshua Stein Vice President Accounting and Financial Management December 19, 2018
Joshua Stein Vice President Accounting and Financial Management 202-663-5318 Russell G. Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Via email:
More informationMarch 9, Susan M. Cosper, CPA Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT
March 9, 2017 Susan M. Cosper, CPA Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Re: FASB January 10, 2017 Proposed Accounting Standards Update Inventory (Topic 330): Disclosure
More informationComments on the Exposure Draft Financial Instruments: Amortised Cost and Impairment
June 30, 2010 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir or Madame, Comments on the Exposure Draft Financial Instruments: Amortised Cost and Impairment
More informationSeptember 30, Ms. Leslie F. Seidman Acting Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
Ms. Leslie F. Seidman Acting Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06865-5116 Re: Proposed Accounting Standards Update, Accounting for Financial Instruments
More informationProject No. 26-4P Preliminary Views of the Governmental Accounting Standards Board, Accounting and Financial Reporting for Derivatives
Deloitte & Touche LLP Ten Westport Road PO Box 820 Wilton, CT 06897-0820 Mr. David R. Bean Director of Research and Technical Activities, Governmental Accounting Standards Board 401 Merritt 7 P.O. Box
More informationFile Reference Number , Invitation to Comment, Selected Issues about Hedge Accounting
April 25, 2011 Ms. Susan M. Cosper Director of Technical Application and Implementation Activities Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Re: File Reference
More informationComment Letter No. 4. hulu. 7 December 2018
7 December 2018 Technical Director - Submitted to director@fasb.org File Reference No. Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Re: File Reference No., Proposed
More informationApril 15, Russell G. Golden Chairman Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
Donna J. Fisher Senior Vice President Tax, Accounting & Financial Management (202) 663-5318 DFisher@aba.com April 15, 2016 Russell G. Golden Chairman Financial Accounting Standards Board 401 Merritt 7
More informationFile Reference: No , Exposure Draft: Revenue from Contracts with Customers
Intel Corporation 2200 Mission College Blvd. Santa Clara, CA 95052-8119 Tel: 408-765-8080 Fax: 408-765-8871 March 13, 2012 Leslie Seidman, Chairman Financial Accounting Standards Board 401 Merritt 7 P.
More informationOctober 17, Susan M. Cosper, Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT Via to
October 17, 2016 Susan M. Cosper, Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Via Email to director@fasb.org Grant Thornton Tower 171 N. Clark Street, Suite 200 Chicago, IL
More informationFile Reference No : Proposed Accounting Standards Update (Revised), Revenue Recognition (Topic 605), Revenue from Contracts with Customers
Richard D. Levy MAC A0163-039 Executive Vice President & Controller 343 Sansome Street, 3rd Floor San Francisco, CA 94104 415 222-3119 415 975-6871 Fax richard.d.levy@wellsfargo.com Ms. Leslie F. Seidman
More informationU.S. GAAP & IFRS: Today and Tomorrow Sept , New York. Financial Instruments
U.S. GAAP & IFRS: Today and Tomorrow Sept. 13-14, 2010 New York Financial Instruments Donald Doran Society of Actuaries US GAAP Seminar Financial Instruments Joint Project September 14, 2010 *connectedthinking
More informationFile Reference No Re: Proposed Accounting Standards Update, Premium Amortization on Purchased Callable Debt Securities
Deloitte & Touche LLP 695 East Main Street Stamford, CT 06901-2141 Tel: +1 203 708 4000 Fax: +1 203 708 4797 www.deloitte.com Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board
More informationThe IASB s Exposure Draft Hedge Accounting
Date: 11 March 2011 ESMA/2011/89 IASB Sir David Tweedie Cannon Street 30 London EC4M 6XH United Kingdom The IASB s Exposure Draft Hedge Accounting The European Securities and Markets Authority (ESMA) is
More informationRe: December 20, 2012 Exposure Draft of a Proposed Accounting Standards Update (ASU), Financial Instruments Credit Losses (Subtopic )
June 5, 2013 Susan M. Cosper, CPA Technical Director FASB 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Re: December 20, 2012 Exposure Draft of a Proposed Accounting Standards Update (ASU), Financial
More informationWe would like to offer the following general observations in connection with this proposed ASU.
February 14, 2012 Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 File Reference No. 2011-210 Dear Ms. Cosper: The Financial Reporting Executive
More informationTel: ey.com
Ernst & Young LLP 5 Times Square New York, NY 10036 Tel: +1 212 773 3000 ey.com Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116
More informationDerivatives and Hedging (Topic 815)
No. 2017-12 August 2017 Derivatives and Hedging (Topic 815) Targeted Improvements to Accounting for Hedging Activities An Amendment of the FASB Accounting Standards Codification The FASB Accounting Standards
More information