Archives for Accounting & Auditing

Letter to the PCAOB regarding Proposed Auditing Standards (12/9/2013)

Date: December 9, 2013

Issue: Auditing

To:  PCAOB

Filing Type: Regulatory 

Description: Accordingly, the CCMC believes that the Proposal does not meet minimum thresholds required to move forward. Instead, the CCMC respectfully requests the PCAOB should work with the Securities and Exchange Commission (“SEC”) and Financial Accounting Standards Board (“FASB”) to move forward on a broad agenda of financial reporting modernization as outlined in the CCMC’s letter October 9, 2013 to SEC Chair Mary Jo White.

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Letter to Secretary Lew regarding audit firm rotation (11/26/2013)

Date: November 26, 2013

Issue: Auditing

To: U.S. Department of the Treasury

Filing: Regulatory 

Description: CCMC is concerned about potential adverse ramifications if the European Union imposes audit firm rotation and caps on permissible non-audit services. 

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Regulatory Capital Rules: Regulatory Capital, Enhanced Supplementary Leverage Ratio Standards for Certain Bank Holding Companies and their Subsidiary Insured Depository Institutions

Date: September 23, 2013

Issue: Accounting and Auditing

To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency

Filing TypeRegulatory

Description:  The CCMC is concerned that the proposed leverage ratio rules are premature. The Bank for International Settlements (“BIS”) has issued for comment a discussion paper on The Regulatory Framework: Balancing Risk Sensitivity, Simplicity and Comparability (“Basel III capital simplification paper”) in an effort to reduce the complexity and opaqueness of the Basel III capital agreements (Basel III”). Furthermore, the Federal Reserve has not yet completed the final promulgation of the rules implementing section 165 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). The proposed leverage ratios are also creating a divergence from international standards. The Chamber also wishes to express concerns that the proposed leverage ratio rules may adversely impact the ability of businesses to attractcapital harming their ability to grow and create jobs

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Coalition Letter on Low-Income Housing Tax Credits

Date: February 25, 2013

IssueAccounting and Auditing

To: Emerging Issues Tax Force Members

Filing Type: Regulatory

Description: A Coalition of more than 60 organizations submitted a letter to the members of Emerging Issues Task Force (EITF) in advance of their March 14th meeting where they will consider a change in the accounting treatment for low-income housing tax credits (LIHTC).

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Exposure Draft: Responding to a Suspected Illegal Act

Date: January 3, 2013

IssueAccounting and Auditing

To: International Ethics Standards Board for Accountants

Filing Type: Regulatory

Description: CCMC submitted comments to the International Ethics Standards Board for Accountants regarding its exposure draft “responding to a suspected illegal act”.  While CCMC strongly believes that lawbreakers should be punished, we believe the current exposure draft should be modified to reflect the predominant role of national legal authorities and to avoid adverse consequences that may degrade information gathering needed for transparent and relevant financial reports. The letter outlines a handful of steps that a professional accountant should be expected to take, in appropriate circumstances, to report suspected illegal acts.

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