Date: January 13, 2017
Issue: Accounting; International
To: Basel Committee on Banking Supervision
Filing Type: Comment Letter
Description: CCMC submitted comments regarding the Consultative Document and related Discussion Paper on Regulatory Treatment of Accounting Provisions —Interim Approach and Transitional Arrangements. The Consultative Documents recognize the introduction of new accounting standards by the International Accounting Standards Board and the United States Financial Accounting Standards Board that will require the use of expected credit loss (“ECL”) models instead of incurred loss models. CCMC urges the Committee not to move forward with any changes in regulatory treatment until banks have had a chance in the United States and elsewhere to see how ECL accounting and other expected credit loss metrics are actually working.
Date: September 30, 2016
To: Financial Accounting Standards Board
Filing Type: Comment letter
Description: While the Chamber supports many aims of the proposal, we believe that some elements can be improved, particularly with respect to the term disclosure of “significant” income taxes paid to any country. Additionally, we believe that the proposal would benefit from recognition that disclosure of certain items is either not decision-useful or duplicative of existing SEC requirements, like cash held abroad and certain income-tax related items, and may be motivated by interests outside of the scope of the Proposal.
Date: August 15, 2016
Issue: Accounting and Auditing
To: Public Company Accounting Oversight Board (PCAOB)
Filing Type: Regulatory
Description: The CCMC is pleased that the PCAOB has dropped from the Proposal any new requirements on auditor responsibilities for other information outside the financial statements that were included in the prior proposal and is continuing research on these issues. However, the CCMC continues to have serious concerns regarding the Proposal, including that the Proposal
blurs and even weakens lines of corporate governance, especially in cases where open communication may been needed between the audit committee and an external auditor;
may create duplicative disclosures in many cases while risking auditors serving as original sources of information in others; and
may raise the liability for auditors and businesses which ultimately harms investors.
Date: January 13, 2014
To: International Accounting Standards Board
Filing Type: International
Description: CCMC submitted comments to the International Accounting Standards Board (IASB) regarding its discussion paper on A Review of the Conceptual Framework for Financial Reporting. We appreciate that IASB is developing a complete and updated set of concepts to use when it develops or revises IFRS. This is an important step in the development and sustainment of a high quality global accounting system. The letter provides additional comments related to convergence as well as other matters, including cost-benefit considerations, forward-looking information, other comprehensive income and the use of the business model concept in financial reporting.
Date: September 23, 2013
To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency
Filing Type: Regulatory
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.