Archives for Accounting and Auditing

Letter to the Basel Committee regarding Regulatory Treatment of Accounting Provisions (1/13/17)

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.

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Letter to FASB regarding accounting standards update on income taxes (9/30/16)

Date: September 30, 2016

Issue: Accounting

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.

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Letter to the PCAOB regarding Proposed Auditing Standard on The Auditor’s Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion (8/15/16)

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

  1. 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;
  2. may create duplicative disclosures in many cases while risking auditors serving as original sources of information in others; and
  3. may raise the liability for auditors and businesses which ultimately harms investors.

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Letter to IASB on Conceptual Framework Discussion Paper (1/13/14)

Date:  January 13, 2014 

Issue: Accounting

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.

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Letter to Federal Reserve, FDIC, and OCC regarding proposed leverage ratio rules (9/23/2013)

Date: September 23, 2013

Issue:  Accounting

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.

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