Archives for IASB

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.

Download PDF

Letter to IAASB Regarding Exposure Draft on Reporting on Audited Financial Statements (11/20/2013)

Date: November 20, 2013

Issue: Auditing 

To: International Auditing and Assurance Standards Board

Filing Type: Regulatory

Description: CCMC submitted a letter to the IAASB expressing concerns with the proposed new and revised international auditing standards. Unfortunately, many of the concerns we expressed last year, still remain. Specifically, the Proposal changes the role of the auditor and obscures the lines of responsibility established by corporate governance policies. If enacted, the proposals would enhance the liability profiles for auditors and companies and promote a chilling effect on the ability of auditors to exercise judgment and perform their critical duties for businesses and investors.

Download PDF

Lease Accounting Coalition Letter to FASB and IASB (9/9/2013)

Date: September 9, 2013

Issue: Accounting

To:  Russ Golden, Chairman,Financial Accounting Standards Board and the Honorable Hans Hoogervorst,  Chairman, International Accounting Standards Board

Filing Type: Coalition letter

Description: This letter was submitted on behalf of the Lease Accounting Coalition to FASB and IASB on their leases accounting standards. The coalition believe that the proposed leasing standard may increase financial reporting complexity, impose substantial costs on businesses, lack any benefits for investors and drive economic activity rather than reflect it.

Download PDF



Letter to FASB and IASB regarding Leases (9/10/2013)

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.

Download PDF



FASB Financial Instruments Credit Losses; IASB Financial Instruments Expected Credit Losses

Date: March 25, 2013

IssueAccounting and Auditing

To: Financial Accounting Standards Board and International Accounting Standards Board

Filing Type: Regulatory

Description: A letter to FASB and IASB,FIRCA  requesting an extension to the FASB Financial Instruments Credit Losses comment period.

Download PDF