The U.S. Chamber of Commerce (“Chamber”) appreciates the opportunity to comment on the Financial Accounting Standards Board (“FASB” or “Board”) Exposure Draft on the Proposed Accounting Standards Update (“ASU”) on Income Statement – Reporting Comprehensive Income – Expense Disaggregation Disclosures (Subtopic 220-40) – Disaggregation of Income Statement Expenses (“Proposal,” “Proposed ASU,” “Proposed Update,” or “Exposure Draft”).
The Proposed ASU would require all public business entities (“public companies”) to provide a financial statement footnote (“footnote” or “note”) disclosing very detailed, disaggregated quantitative information, in a tabular format, for specified categories underlying certain expense captions, along with additional qualitative information. The footnote disclosures would apply to both annual and interim reporting periods and encompass all three years of comparative income statements.
The Proposal would not change or remove any existing expense disclosure requirements or change requirements for presentation of expenses on the face of the income statement. While maintaining existing presentation and disclosure requirements, the Proposal would require companies to duplicate existing disclosures of other specified expenses, gains, and losses by including them in the tabular format. Although described as a new footnote in tabular format, essentially, the Proposed ASU creates a new financial statement – the Statement of Disaggregated Expenses, Gains, and Losses Before Taxes.