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US Week in Review - Week ending 27 September 2012

The US Week in Review highlights this week’s developments and emerging issues in the financial reporting world and gives you direct access to relevant technical accounting guidance and thought leadership produced by Ernst & Young.

Ernst & Young publications


2012 SEC Comments and Trends publication

Every year, we track the SEC staff's comments on public company filings to provide you with insights on the staff's areas of focus. Understanding the issues discussed in our 2012 SEC Comments and Trends publication can help as you head into the year-end reporting season.

While the SEC staff continues to comment on topics such as significant estimates, revenue recognition, impairment and financial instruments, it has increased its focus on areas such as pro forma financial information and the presentation of guarantor condensed consolidating information. The staff also continues to focus on segment reporting, loss contingency disclosures, the effects on liquidity of indefinitely reinvesting foreign earnings and exposure to European debt.

Our publication discusses matters that relate to all registrants, as well as matters that relate to specific industries and foreign private issuers. It also includes a section on best practices when responding to comment letters from the SEC staff.

Comment letter on liquidity risk and interest rate risk disclosures

In our comment letter on the FASB's proposal to require all entities to provide disclosures about their exposures to liquidity risk and interest rate risk, we explain why we do not support finalizing the proposal in its current form. We believe that many of the proposed disclosures are redundant given current SEC reporting requirements. Additionally, we believe that nonpublic and not-for-profit entities should be exempted from the proposed update because we don't believe the incremental benefits outweigh the costs of compliance.


Standard Setter updates


Financial Accounting Standards Board (FASB)

24 September 2012 joint FASB-IASB videoconference meeting

The Boards discussed their projects on:

  • Insurance contracts
  • Revenue recognition

For details, see the FASB Action Alert.

25 September 2012 FASB meeting

The FASB discussed its Leases project.

For details, see the FASB Action Alert.

27 September 2012 joint FASB-IASB videoconference meeting

The Boards continued to discuss the Revenue recognition project.

For details, see the FASB Action Alert.

27 September 2012 FASB meeting

The FASB approved the three consensuses and two consensuses-for-exposure reached at the 11 September 2012 EITF meeting.

For details, see the FASB Action Alert.

Upcoming meetings and webcasts

3 October 2012 FASB meeting

The FASB is scheduled to discuss:

  • Accounting for financial instruments: impairment
  • Accounting for financial instruments: classification and measurement
  • Transfers and servicing: repurchase agreements and similar transactions
  • Insurance contracts

For additional details, see the FASB calendar.

Education sessions

See the FASB calendar for upcoming education sessions. No decisions are made at these sessions.

Securities and Exchange Commission (SEC)

EDGAR accepting confidential draft registration statements on 1 October

The SEC has modified EDGAR to accept confidential submissions of draft registration statements beginning 1 October 2012. The current secure email system still will be available for confidential submissions until the effective date of the EDGAR Filer Manual for EDGAR Release 12.2.

The new system will allow emerging growth companies and eligible foreign private issuers to electronically file previously submitted draft registration statements instead of including them as exhibits to their first publicly filed registration statements.

Instructions and Frequently Asked Questions are available on the SEC's website.

Suggestions solicited for this year's Forum on Small Business Capital Formation

The SEC is requesting public comment for agenda topics for its annual Government-Business Forum on Small Business Capital Formation on 15 November 2012 at the SEC's headquarters in Washington, DC. The forum will focus on the Jumpstart Our Business Startups Act and issues not covered by the act.

The morning panel discussions will be webcast on the SEC's website. The afternoon breakout sessions will be available via teleconference for registered participants.

Other reminders

SEC Comments and Trends webcast to air on 2 October

There is still time to register for our SEC Comments and Trends webcast on 2 October 2012 from 1 p.m. to 2 p.m. Eastern time. This program will provide you with insights into the SEC comment letter process, including common areas of focus and emerging topics.

The webcast, which coincides with Ernst & Young's annual SEC Comments and Trends publication, will feature Martin Dunn, a partner at O'Melveny & Myers LLP and former Deputy Director of the SEC's Division of Corporation Finance, and a panel of Ernst & Young LLP Professional Practice partners and former SEC staffers. They will lead an interactive discussion of firsthand experiences, observations and lessons from the SEC comment letter process to help you as you head into the year-end reporting season. Discussion topics will include:

  • A behind-the-scenes look at the SEC's filing review process
  • SEC comment letter trends
  • Emerging areas of focus expected in the upcoming reporting season

To register, go to SEC Comments and Trends.

Upcoming Thought center webcasts and podcasts


SEC comments and trends: an analysis of current reporting issues 
2 October 2012, 1:00 p.m. Eastern time

Evolving role of today's CFO
Featured in FEI's CFO Community of Interest
Hosted by Ernst & Young LLP
16 October 2012, 12:00 p.m. Eastern time

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