Date: September 10, 2013

Issue: Lease Accounting

To: Financial Accounting Standards Board and International Accounting Standards Board

Filing Type: Regulatory

Description:  The CCMC has several serious issues concerning the proposal specifically: 1. Continued lack of investor support and failure to transparently identify investor interests that are being addressed; 2. Increased footnote disclosure may be as beneficial as balance sheet capitalization; 3. Straight line expensing should be used for both equipment and real estate leases; 4. Compliance burdens that place costs upon businesses without benefits to investors; 5. Driving economic activity rather than reflecting it; and 6. Due process and transition issues.

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