The SEC's new whistleblower program, created under rulemaking implementing the Dodd-Frank Act, is effective today. See the SEC's press release issued this morning: SEC's New Whistleblower Program Takes Effect Today, which links in turn to the SEC's central portal for reporting as a whistleblower and related info: www.sec.gov/whistleblower.
See also this Introduction by Office of the Whistleblower Chief Sean McKessy, and McKessy's remarks 8.11.11 at Georgetown University. Props to Dave Lynn of TheCorporateCounsel.net Blog for the heads up in his post earlier today: W-Day is Here: The SEC's Whistleblower Rules Are Now Effective.
Friday, 12 August 2011
Thursday, 11 August 2011
FASB Approves Simplification Of Goodwill Impairment Testing
At its board meeting yesterday, FASB approved an amendment to its standards which will simplify testing for goodwill impairment. According to FASB's press release, the Accounting Standards Update, expected to be issued in September, will be effective for annual and interim goodwill impairment tests performed for fiscal years beginning after December 15, 2011, and early adoption will be permitted.
Amendment Suggested By Private Cos; Will Be Available To All Cos.
FASB Board Member Daryl Buck, who joined the board earlier this year with a wealth of private company experience, including, most recently, as SVP and CFO of Reasor's Holding Company, explained in FASB's press release:
Qualitative Assessment
To simplify the goodwill impairment test, a qualitative assessment will be permitted to determine if the two-step quantitative goodwill impairment test is needed. As further described in FASB's press release (reformatted to bullets):
Amendment Suggested By Private Cos; Will Be Available To All Cos.
FASB Board Member Daryl Buck, who joined the board earlier this year with a wealth of private company experience, including, most recently, as SVP and CFO of Reasor's Holding Company, explained in FASB's press release:
The Board’s decision today comes as a direct result of what we heard from private companies, which had expressed concerns about the cost and complexity of performing the goodwill impairment test. The amendments approved by the Board address those concerns and will simplify the process for public and nonpublic entities alike.
Qualitative Assessment
To simplify the goodwill impairment test, a qualitative assessment will be permitted to determine if the two-step quantitative goodwill impairment test is needed. As further described in FASB's press release (reformatted to bullets):
- An entity no longer will be required to calculate the fair value of a reporting unit unless the entity determines, based on a qualitative assessment, that it is more likely than not that its fair value is less than its carrying amount.
- The guidance also includes examples of the types of factors to consider in conducting the qualitative assessment.
- Prior to today’s decision, entities were required to test goodwill for impairment, on at least an annual basis, by first comparing the fair value of a reporting unit with its carrying amount, including goodwill. If the fair value of a reporting unit is less than its carrying amount, then the second step of the test is to be performed to measure the amount of impairment loss, if any.
The goodwill testing simplification approved by FASB yesterday, emphasizing what some would view as a principles based, qualitative approach with example factors to consider, aims at reducing unnecessary complexity in financial reporting. If you haven't seen it, check out our 'music video' on this subject.
PCAOB To Vote Next Week Whether To Issue Concept Release On Auditor Independence
The PCAOB will vote next week on whether to issue a Concept Release for public comment on Auditor Independence and Audit Firm Rotation. (For background, see our earlier post, PCAOB To Consider Mandatory Audit Firm Rotation.) The vote is set to take place at an open meeting Tues. Aug. 16 at 9:30 a.m.; the meeting will be webcast.
According to the PCAOB's press release announcing next week's meeting, the Concept Release being considered would address:
The reason why I assert the above, is because a Concept Release is not formal rulemaking per se, but an early opportunity for public comment on an issue(s), which in turn provides insight to the PCAOB in determining if, when and how to go to the next step of proposed standard-setting.
Speaking generally, (not about this Concept Release specifically), if some matters described in a Concept Release elicit comment that a better solution would be through means other than new standard-setting - e.g., if a proposed solution appears to be burdensome and/or ineffective for a majority of audit firms/issuers/investors, and moreso, if it appears to be a solution in search of a problem; or if the perceived problem could be better addressed through enforcement of existing standards, or through improvements that can be achieved via best practices. Additionally, there is an interplay to be considered between the PCAOB's Auditor Independence standards, and those of the SEC. (As background, the SEC has some archived material on this subject, as of 2001.)
In considering the likely issuance of the Concept Release on Auditor Independence next week, and preparing comment letters thereon, it will also be important to consider potential changes not only to how audits are conducted, but also the product of the audit. In that vein, keep in mind the September 30 comment deadline for another Concept Release issued by the PCAOB earlier this year, on the Auditor's Reporting Model.
According to the PCAOB's press release announcing next week's meeting, the Concept Release being considered would address:
ways that auditor independence, objectivity, and professional skepticism could be enhanced, including mandatory audit firm rotationI believe (please note the disclaimer on the right side of this blog) we can be reasonably assured that the PCAOB board will vote to issue the above Concept Release. In fact, I believe it is more likely than not that board's vote will be unanimous in favor of issuing the Concept Release.
The reason why I assert the above, is because a Concept Release is not formal rulemaking per se, but an early opportunity for public comment on an issue(s), which in turn provides insight to the PCAOB in determining if, when and how to go to the next step of proposed standard-setting.
Speaking generally, (not about this Concept Release specifically), if some matters described in a Concept Release elicit comment that a better solution would be through means other than new standard-setting - e.g., if a proposed solution appears to be burdensome and/or ineffective for a majority of audit firms/issuers/investors, and moreso, if it appears to be a solution in search of a problem; or if the perceived problem could be better addressed through enforcement of existing standards, or through improvements that can be achieved via best practices. Additionally, there is an interplay to be considered between the PCAOB's Auditor Independence standards, and those of the SEC. (As background, the SEC has some archived material on this subject, as of 2001.)
In considering the likely issuance of the Concept Release on Auditor Independence next week, and preparing comment letters thereon, it will also be important to consider potential changes not only to how audits are conducted, but also the product of the audit. In that vein, keep in mind the September 30 comment deadline for another Concept Release issued by the PCAOB earlier this year, on the Auditor's Reporting Model.
Friday, 5 August 2011
Big GAAP/Little GAAP: A 'Big Deal'
The FAF's consideration of whether and how to establish differential accounting standards for public vs. private companies, referred to colloquially as Big GAAP/Little GAAP, has great import for private companies and the users of their financial statements in particular, and is of interest to public companies and the U.S. Securities and Exchange Commission as well, as noted in SEC Chief Accountant Jim Kroeker's June 5 speech at USC.
Before continuing, please note the disclaimer posted on the right side of this blog.
When we last covered this subject in July, we noted that over 1,100 comment letters had been filed with the FAF, a majority of which constituted variations of a form letter with points said by some to have been circulated by the AICPA, backing the recommendation of a broad-based Blue Ribbon Panel on private co. standard-setting (a panel co-sponsored by the FAF, AICPA and NASBA), which concluded that a new standards board should be established under the FAF to focus on private company standard-setting.
We also noted that not all comment letters held that view, in fact the letter filed by FEI's Committee on Private Company Standards, in an April comment letter, took the recommendation of the Blue Ribbon Panel and modified it to some extent, by suggesting that the FAF form a Private Company Task Force (PCTF), structured and empowered to participate in the standard-setting process in a similar manner to FASB's Emerging Issues Task Force (EITF).
During the last few weeks in July, another 500 comment letters were filed with the FAF on this topic. (See all comment letters filed to date.)
In an article published earlier this week, Private Co. GAAP Heats Up, (subtitled: An intense lobbying effort to keep new standards for private companies out of FASB's grasp is under way), CFO.com's Alix Stuart writes:
Stuart observed that of the over 1,500 comment letters so far, there were "multiple submissions from many CPA firms and predominantly in boilerplate language. Most appear to be in favor of a separate board, for various reasons. ... the AICPA provides a Mad Libs–style letter template with phrases and sentences for commenters to plug in... Notably, however, Finance Executives International's Committee on Private Company Standards submitted the first letter, in April, opposing the idea. 'Working within. . .the FASB would avoid some of the implementation issues that would require state recognition of a new standard setting body' and would also be less expensive, the letter noted."
NVCA, NYSSCPA, MACPA, NCCPAP Letters
Of the more recent comment letters filed, some have very powerful arguments, and are very instructive as to how, in some cases, certain constituencies (such as the National Venture Capital Association) have strongly held views calling for a separate standards board for private companies. NVCA's letter, signed by its President, Mark Heesen, included 76 additional venture cap member signatories, and states:
The New York State Society of CPAs struggled with a nearly split view on the question of whether or not there should be an entirely separate standards board for private companies, although a majority of its members and leadership polled agreed there should be differential standards for private companies, by developing more exceptions and modifications of GAAP (vs. developing a new set of private company GAAP), and in the end, following the recommendation of a slight majority of its leadership, recommended forming a separate or 'autonomous' standards board for private company standards, in part because:
Others, such as the Maryland Association of CPAs, supported their call for a new standard-setting board for private companies with a white paper prepared by MACPA's Accounting Standards Task Force. The white paper summarized input from discussions held with over 1,500 MACPA members at town hall meetings in which:
MACPA's white paper also notes that while "A majority of the Task Force wanted the separate board to have ultimate authority over standards decisions for private companies," there was a dissenting opinion in favor of forming a group similar to the EITF instead (a position advocated by FEI's CPC-S in its own letter earlier this year, as noted above).
The National Conference of CPA Practitioners (NCCPAP) also weighs in, stating:
Short-term actions taking place
As the FAF continues to review comment letters and conduct additional outreach to constituents as it deliberates this issue, as previously reported, FASB committed to taking a number of short-term steps, including some recommended by the Blue Ribbon Panel, to enhance its consideration of private company concerns.
One such step includes convening public roundtables to get input specifically from private companies, such as those announced for October, which we reported on here.
Before continuing, please note the disclaimer posted on the right side of this blog.
When we last covered this subject in July, we noted that over 1,100 comment letters had been filed with the FAF, a majority of which constituted variations of a form letter with points said by some to have been circulated by the AICPA, backing the recommendation of a broad-based Blue Ribbon Panel on private co. standard-setting (a panel co-sponsored by the FAF, AICPA and NASBA), which concluded that a new standards board should be established under the FAF to focus on private company standard-setting.
We also noted that not all comment letters held that view, in fact the letter filed by FEI's Committee on Private Company Standards, in an April comment letter, took the recommendation of the Blue Ribbon Panel and modified it to some extent, by suggesting that the FAF form a Private Company Task Force (PCTF), structured and empowered to participate in the standard-setting process in a similar manner to FASB's Emerging Issues Task Force (EITF).
During the last few weeks in July, another 500 comment letters were filed with the FAF on this topic. (See all comment letters filed to date.)
In an article published earlier this week, Private Co. GAAP Heats Up, (subtitled: An intense lobbying effort to keep new standards for private companies out of FASB's grasp is under way), CFO.com's Alix Stuart writes:
At least 15 state CPA societies, including those in Alabama, Illinois, New Jersey, and New York, have sent letters to the FAF urging a separate board, according to Maryland Association of CPAs CEO Tom Hood, who also penned a letter. ...“This issue has been around for 30 years, and this is a once-in-a-lifetime chance to get it right,” says Hood. “If it doesn’t happen now, it will never happen.”
Stuart observed that of the over 1,500 comment letters so far, there were "multiple submissions from many CPA firms and predominantly in boilerplate language. Most appear to be in favor of a separate board, for various reasons. ... the AICPA provides a Mad Libs–style letter template with phrases and sentences for commenters to plug in... Notably, however, Finance Executives International's Committee on Private Company Standards submitted the first letter, in April, opposing the idea. 'Working within. . .the FASB would avoid some of the implementation issues that would require state recognition of a new standard setting body' and would also be less expensive, the letter noted."
NVCA, NYSSCPA, MACPA, NCCPAP Letters
Of the more recent comment letters filed, some have very powerful arguments, and are very instructive as to how, in some cases, certain constituencies (such as the National Venture Capital Association) have strongly held views calling for a separate standards board for private companies. NVCA's letter, signed by its President, Mark Heesen, included 76 additional venture cap member signatories, and states:
As an asset class committed to investing in America’s most promising private companies, the venture capital industry understands the importance of
accurate, transparent and meaningful financial reporting practices. While
tremendous advances in information technology have been made in the last
decade, the same can not be said for private company accounting standards
which have been wrongly based on public company practices for too long. Private company standards have become both burdensome and irrelevant, rendering them costly for preparers and meaningless for users. As investors in these companies we assert that the situation has become untenable and must be addressed.
On behalf of our firms and portfolio companies, we support the creation of a separate private company board with standard-setting authority under the Financial Accounting Foundation’s oversight. Through this independent board, appropriate modifications to existing U.S. GAAP (generally accepted accounting principles) for private companies would be driven to reflect their financial statement users’ unique needs.
It has become clear that the Financial Accounting Standards Board (FASB), despite past efforts, is not able to adequately address the issues faced by private companies... Applying accounting standards designed for public entities diverts precious private company resources to meet standards which result in statements which are not relevant, reliable, nor comparable. A private company board comprised of members with constituent experience would be best positioned to recognize the important needs of private company reporting. Such a group would also be able to ensure an effective and useful path to public company accounting
principles as a company moves toward becoming public. If left unaddressed, current private company accounting practices will continue to negatively
impact our country’s emerging growth companies. At a time when economic recovery is paramount, we must be do all we can to ensure that financial reporting is efficient, effective and relevant for all stakeholders. ...
We applaud the FAF’s recognition of these issues and its wisdom in forming the Blue Ribbon Panel and strongly encourage the adoption of the panel’s recommendations. Anything short of adoption would be at the expense of US private companies.
The New York State Society of CPAs struggled with a nearly split view on the question of whether or not there should be an entirely separate standards board for private companies, although a majority of its members and leadership polled agreed there should be differential standards for private companies, by developing more exceptions and modifications of GAAP (vs. developing a new set of private company GAAP), and in the end, following the recommendation of a slight majority of its leadership, recommended forming a separate or 'autonomous' standards board for private company standards, in part because:
there is not a proper weighing of costs and benefits in setting standards for private companies and there is a need for more relevant financial statements for private companies and their financial statement users. Given the public company reporting pressures placed upon the FASB, the Board cannot adequately respond to the competing needs of the private company sector.
Others, such as the Maryland Association of CPAs, supported their call for a new standard-setting board for private companies with a white paper prepared by MACPA's Accounting Standards Task Force. The white paper summarized input from discussions held with over 1,500 MACPA members at town hall meetings in which:
More than 90 percent of members polled ... believed GAAP modifications and
exceptions for private companies are the best solution to the problem... [and
that MACPA's] Task Force agreed that a separate board for private companies
is warranted
MACPA's white paper also notes that while "A majority of the Task Force wanted the separate board to have ultimate authority over standards decisions for private companies," there was a dissenting opinion in favor of forming a group similar to the EITF instead (a position advocated by FEI's CPC-S in its own letter earlier this year, as noted above).
The National Conference of CPA Practitioners (NCCPAP) also weighs in, stating:
Based on our collective experience and knowledge of the profession, we feel that a separate, autonomous regulatory standard setting body is the only acceptable answer to address these issues. The body should come under the jurisdiction of the FAF without the need for FASB approval.
Short-term actions taking place
As the FAF continues to review comment letters and conduct additional outreach to constituents as it deliberates this issue, as previously reported, FASB committed to taking a number of short-term steps, including some recommended by the Blue Ribbon Panel, to enhance its consideration of private company concerns.
One such step includes convening public roundtables to get input specifically from private companies, such as those announced for October, which we reported on here.
FASB Invites Private Cos. to Public Roundtable
FASB issued a call yesterday for representatives from private companies to speak at public roundtables on "issues relating to existing private company accounting and reporting standards." Separately, FEI launched a program earlier this year called the "Private Company Roundtable."
Private Co. Input Sought on Need For Differention in Existing GAAP
Two such roundtables seeking private company input on existing GAAP will be convened, on October 11 in Chicago, and October 17 in San Francisco. The purpose of the October roundtables, following on similar roundtables held last year, was described by FASB Chairman Leslie Seidman in FASB's press release as follows:
Topics to be addressed at FASB's October roundtables, according to the board, "are expected to include, but will not be limited to, accounting and disclosure requirements relating to:
- variable interest entities,
- interest rate swaps, and
- level 3 fair value measurements
Private company stakeholders (preparers, auditors, users of private company financial statements, and others) interested in being considered as a participant in FASB's October roundtables need to complete this online application form by September 13.
Join FEI's Private Company Roundtable
Speaking of 'roundtables' and private companies, Financial Executives International, an association of senior financial executives, launched an outreach program last year called the "Private Company Roundtable" (PCR).
The PCR, building on the success of FEI's Committee on Private Company Policy, and Committee on Private Company Standards, has met with great success in providing an avenue for private companies to participate in educational, networking, and advocacy opportunities, through conference calls, webcasts and an upcoming Town Hall meeting.
The PCR is open to all interested FEI members, whereas membership in CPC-P, CPC-S and FEI's other national technical committees is more limited.
Participants in FEI's Private Company Roundtable can:
- Join fellow members in quarterly conference calls to discuss important private company topics and hear from high-ranking government officials and technical experts.
- Receive initiations to participate in discussions regarding finance policy issues and critical-interest topics with Congressional members, Administration officials, and senior staffers.
- Provide feedback on business operations and the potential business impact of policies to assist FEI in the formulation of policy positions and strategic education and advocacy efforts.
- Offer support on critical issues through targeted correspondence to policy-makers regarding information that is timely and pertinent to private companies.
FEI Private Company Roundtable's Townhall Sept. 26;
FEI Washington Policy Conference Sept. 26-27
FEI's Private Company Roundtable is hosting its inaugural in-person Town Hall meeting on September 26, in advance of the 2nd annual FEI Washington Policy Conference (of interest to public companies and private companies) on Sept. 26-27. Read more about these programs here.
Private Co. Input Sought on Need For Differention in Existing GAAP
Two such roundtables seeking private company input on existing GAAP will be convened, on October 11 in Chicago, and October 17 in San Francisco. The purpose of the October roundtables, following on similar roundtables held last year, was described by FASB Chairman Leslie Seidman in FASB's press release as follows:
to engage in a constructive dialogue about private company accounting and reporting issues on existing GAAP with a wide variety of stakeholders, including private companies, their CPA practitioners, and users of private company financial statementsSeidman added:
The [FASB] Board and staff found that the two roundtables we held last fall were valuable forums for hearing first hand from private company constituents about their concerns with existing GAAP. Those roundtables provided the impetus for our efforts to develop a differential reporting framework for private companies and our project to simplify goodwill impairment assessments.VIEs, Swaps, Fair Value Among Topics
Topics to be addressed at FASB's October roundtables, according to the board, "are expected to include, but will not be limited to, accounting and disclosure requirements relating to:
- variable interest entities,
- interest rate swaps, and
- level 3 fair value measurements
Private company stakeholders (preparers, auditors, users of private company financial statements, and others) interested in being considered as a participant in FASB's October roundtables need to complete this online application form by September 13.
Join FEI's Private Company Roundtable
Speaking of 'roundtables' and private companies, Financial Executives International, an association of senior financial executives, launched an outreach program last year called the "Private Company Roundtable" (PCR).
The PCR, building on the success of FEI's Committee on Private Company Policy, and Committee on Private Company Standards, has met with great success in providing an avenue for private companies to participate in educational, networking, and advocacy opportunities, through conference calls, webcasts and an upcoming Town Hall meeting.
The PCR is open to all interested FEI members, whereas membership in CPC-P, CPC-S and FEI's other national technical committees is more limited.
Participants in FEI's Private Company Roundtable can:
- Join fellow members in quarterly conference calls to discuss important private company topics and hear from high-ranking government officials and technical experts.
- Receive initiations to participate in discussions regarding finance policy issues and critical-interest topics with Congressional members, Administration officials, and senior staffers.
- Provide feedback on business operations and the potential business impact of policies to assist FEI in the formulation of policy positions and strategic education and advocacy efforts.
- Offer support on critical issues through targeted correspondence to policy-makers regarding information that is timely and pertinent to private companies.
FEI Private Company Roundtable's Townhall Sept. 26;
FEI Washington Policy Conference Sept. 26-27
FEI's Private Company Roundtable is hosting its inaugural in-person Town Hall meeting on September 26, in advance of the 2nd annual FEI Washington Policy Conference (of interest to public companies and private companies) on Sept. 26-27. Read more about these programs here.
FEI Private Co. Town Hall Sept. 26; Washington Policy Conf. Sept. 26-27
On Monday, September 26, 2011, FEI's Private Company Roundtable will host an in-person Town Hall meeting in conjunction with FEI's Washington Policy Conference in Washington, D.C.
FEI's Private Company Roundtable was established to provide a forum for members from private companies to network and discuss private company finance issues. During the past year, the Private Company Roundtable has met virtually, by conference call, and hosted numerous speakers from policy making positions on Capitol Hill.
The upcoming Town Hall meeting will be the first in-person meeting of the Private Company Roundtable. Set to take place from 2:00pm-5:00pm on September 26, the Town Hall meeting will include high-level policy speakers and an opportunity to meet, dialogue, and network with fellow FEI Private Company Roundtable members.
For those members of the Private Company Roundtable that are interested in arriving to Washington early on September 26th, FEI is planning meetings on Capitol Hill, as well as an optional lunch to round out the visit.
Oxley, Blanchard, Castle, Malek Keynote Washington Policy Conference
Following the PCR Town Hall meeting, a reception will kick-off FEI's Washington Policy Conference on the evening of September 26, continuing with a full day of programming on September 27th.
The 2nd annual Washington Policy Conference, of interest to public company and private company financial executives, brings together key business and government leaders to provide insight into policy questions facing senior financial executives and their companies.
Topics include the policy impacts of reigning in the deficit, prospects of fundamental tax reform and the impact of new legislation and regulations currently being debated.
Keynote speakers at FEI's Washington Policy Conference include Mike Oxley, former Chairman of the House Financial Services Committee; Fred Malek, former President of Marriott Hotels and Northwest Airlines; Mike Castle, former Member of Congress (R-DE) and former Governor of Delaware; and James Blanchard, former Member of Congress (D-MI) and former Governor of Michigan.
Learn more about FEI membership; see the detailed agenda and register for:
FEI's Private Company Roundtable Town Hall, Sept. 26, Washington DC
FEI's Washington Policy Conference, Sept. 26-27, Washington DC
FEI's Private Company Roundtable was established to provide a forum for members from private companies to network and discuss private company finance issues. During the past year, the Private Company Roundtable has met virtually, by conference call, and hosted numerous speakers from policy making positions on Capitol Hill.
The upcoming Town Hall meeting will be the first in-person meeting of the Private Company Roundtable. Set to take place from 2:00pm-5:00pm on September 26, the Town Hall meeting will include high-level policy speakers and an opportunity to meet, dialogue, and network with fellow FEI Private Company Roundtable members.
For those members of the Private Company Roundtable that are interested in arriving to Washington early on September 26th, FEI is planning meetings on Capitol Hill, as well as an optional lunch to round out the visit.
Oxley, Blanchard, Castle, Malek Keynote Washington Policy Conference
Following the PCR Town Hall meeting, a reception will kick-off FEI's Washington Policy Conference on the evening of September 26, continuing with a full day of programming on September 27th.
The 2nd annual Washington Policy Conference, of interest to public company and private company financial executives, brings together key business and government leaders to provide insight into policy questions facing senior financial executives and their companies.
Topics include the policy impacts of reigning in the deficit, prospects of fundamental tax reform and the impact of new legislation and regulations currently being debated.
Keynote speakers at FEI's Washington Policy Conference include Mike Oxley, former Chairman of the House Financial Services Committee; Fred Malek, former President of Marriott Hotels and Northwest Airlines; Mike Castle, former Member of Congress (R-DE) and former Governor of Delaware; and James Blanchard, former Member of Congress (D-MI) and former Governor of Michigan.
Learn more about FEI membership; see the detailed agenda and register for:
FEI's Private Company Roundtable Town Hall, Sept. 26, Washington DC
FEI's Washington Policy Conference, Sept. 26-27, Washington DC
Monday, 1 August 2011
Disclosure Framework, Improving, Integrating Certain FASB, SEC Disclosure Requirements, On Deck for FASB Ed Session This Week
The Financial Accounting Standards Board (FASB) will pick up its discussion of its Disclosure Framework project at an Education Session (Ed session) this Wednesday, August 3. FASB began webcasting its Ed sessions earlier this year, and although no votes are taken, they provide a glimpse of what's on deck for formal discussion at a future FASB board meeting, generally the meeting held the following week. (This week's FASB board meeting, to be held Friday, is on the proposed Accounting Standards Update on Consolidation: Investment Companies.)
Objective: Improve, Integrate GAAP, MD&A Disclosures
As noted in FASB's project summary of the Disclosure Framework project:
Roots of Project in SEC's Pozen Committee; ITAC
The genesis of the Disclosure Framework project, as also noted in FASB's project summary, was to:
The above-named SEC advisory committee, abbreviated CIFiR, and chaired by Robert Pozen, was informally referred to as the Pozen Committee. Today happens to be the third anniversary of the Pozen Committee's report & recommendations; in honor of the Aug. 1 anniversary of that report (and, we understand, (according to wikipedia!) Mr. Pozen's upcoming birthday on Aug. 8), we are pleased to post as a tribute to that committee, the music video, shown above, Hey There Bob Pozen.
Objective: Improve, Integrate GAAP, MD&A Disclosures
As noted in FASB's project summary of the Disclosure Framework project:
The objectives of this project are to (1) establish an overarching framework intended to make financial statement disclosures more effective and coordinated and (2) seek ways to better integrate information provided in financial statements, Management Discussion & Analysis (MD&A), and other parts of a reporting entity’s financial reporting package. The project objective is not intended to be additive but, rather, to develop a framework for improved U.S. Generally Accepted Accounting Principles (GAAP) that promotes meaningful communication and logical presentation of disclosures and avoids unnecessary repetition.
Roots of Project in SEC's Pozen Committee; ITAC
The genesis of the Disclosure Framework project, as also noted in FASB's project summary, was to:
establis[h] an overarching framework intended to make financial statement disclosures more effective, coordinated, and less redundant. The project was
added in response to requests and recommendations received from several constituents, including the Investors Technical Advisory Committee (ITAC) and the Securities and Exchange Commission’s (SEC) Advisory Committee on Improvements to Financial Reporting (Recommendations 1.2 and 1.3).
The above-named SEC advisory committee, abbreviated CIFiR, and chaired by Robert Pozen, was informally referred to as the Pozen Committee. Today happens to be the third anniversary of the Pozen Committee's report & recommendations; in honor of the Aug. 1 anniversary of that report (and, we understand, (according to wikipedia!) Mr. Pozen's upcoming birthday on Aug. 8), we are pleased to post as a tribute to that committee, the music video, shown above, Hey There Bob Pozen.
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