6 September 2016
Comment Letter - ASB’s going concern proposal
In our comment letter, we support the issuance of the Proposed Statement on Auditing Standards, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern, to promote consistency between the auditing standards and ASU 2014-15, Presentation of Financial Statements – Going Concern, which will require management to evaluate whether there is substantial doubt about an entity’s ability to continue as a going concern. However, we disagree with the proposed requirement for the auditor to make inquiries of management about its knowledge of conditions or events beyond the period of management’s evaluation that raise substantial doubt about the entity’s ability to continue as a going concern.
13 July 2016
Auditor involvement with exempt offering documents
The proposed SAS includes performance requirements when the auditor is involved with an exempt offering document. Involvement is determined by a two-benchmark model: (1)The auditor’s report on financial statements or the auditor’s review report on interim financial information is included or incorporated by reference in an exempt offering document, and (2) The auditor performs one or more specified activities with respect to the exempt offering document. Specified activities which trigger involvement are included in the proposed SAS. Although an auditor is not required to become involved in an exempt offering document unless the benchmarks defining involvement are met, auditors are not precluded from becoming voluntarily involved with an offering document in other circumstances. Comments are due by 13 October 2016.
28 June 2016
CAQ tool helps audit committees examine use of non-GAAP measures
The CAQ released a new tool to help audit committees continue to assess management's presentation, outside the audited financial statements, of performance metrics that do not conform to Generally Accepted Accounting Principles (GAAP). The publication can assist in the determination of whether non-GAAP indicators provide investors with meaningful financial information.
14 June 2016
Highlights - CAQ SEC Regulations Committee - 14 June 2016
At this meeting, the SEC staff discussed, among other things, non-GAAP financial measures and related implementation issues, reporting issues related to transition to the new leasing and revenue standards and confirmed that the disclosure threshold for time deposits under the SEC’s Industry Guide 3 is not linked to Federal Deposit Insurance Corporation insurance limit.
23 September 2016
EITF Update - September 2016
The EITF reached a final consensus on restricted cash. The EITF also reached a consensus-for-exposure on accounting for service concession arrangements.
22 July 2016
June 2016 EITF meeting minutes
At this meeting, the Emerging Issues Task Force (EITF) reached a final consensus on classification of certain cash receipts and cash payments. The EITF also reached a consensus-for-exposure on employee benefit plan master trust reporting.
13 October 2016
Comment Letter - ASB’s proposal on auditor involvement with exempt offerings
In our comment letter, we support the issuance of the Proposed Statement on Auditing Standards, Auditor Involvement With Exempt Offering Documents, which would require the auditor to perform certain procedures when the auditor is involved with an exempt offering document. Under the proposal, an auditor would be considered involved when (1) the auditor’s report on the financial statements or the auditor’s review report on interim financial information is included or incorporated by reference in the exempt offering document and (2) the auditor performs one or more specified activities (e.g., issues a comfort letter) with respect to the exempt offering document.
4 October 2016
Comment letter - FASB’s proposed additional technical corrections and improvements to the new revenue standard
In our comment letter, we support the FASB’s objective to address additional feedback received from stakeholders and to make other improvements to its new revenue standard. Overall, we believe that the proposed amendments would address the additional concerns raised by constituents, provide more clarity and improve consistency in application. We also recommend additional clarifications.
5 October 2016
Implementation guide No. 201X-X, Financial reporting for postemployment benefit plans other than pension plans
The objective of this Implementation Guide is to provide guidance that clarifies, explains, or elaborates on the requirements of Statement No. 74, Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans. Comments are due by 19 December 2016.
26 September 2016
Registration is open for 11 October CPE webinar on GASB’s fiduciary activities project
The GASB announced the opening of registration for an upcoming webinar that provides an overview of its proposed guidance on fiduciary activities. In Focus: Update on GASB’s Fiduciary Activities Project will take place on Tuesday, 11 October 2016, from 2:00 to 3:15 p.m. Eastern Daylight Time.
18 August 2016
PCAOB issues annual report on inspections of broker-dealer auditors
The PCAOB issued an annual report on its interim inspection program for auditors of brokers and dealers. The annual report describes results of inspections conducted in 2015, the first inspection year in which all inspected engagements were governed by the SEC’s 2013 amendments to Exchange Act Rule 17a-5, including the new requirement that broker-dealer audits be performed in accordance with PCAOB standards. The report shows high levels of deficiencies similar to inspection results in previous years.
29 July 2016
Comment Letter - PCAOB proposal on audits involving other auditors
In our comment letter, we supported the PCAOB’s efforts to strengthen the requirements for the lead auditor in an audit involving other auditors. However, we suggested that the lead auditor determination needs further study. We also offered some suggestions to make the amendments more scalable based on assessed risk and to allow lead auditors to rely on their firm’s system of quality controls when evaluating other auditors that are in their network.
6 October 2016
SEC in Focus - October 2016
Our latest newsletter summarizes developments related to SEC matters, including certain items we have not previously reported in Week in Review. This issue highlights the SEC staff’s continued focus on non-GAAP financial measures and recent developments in the SEC’s disclosure effectiveness project, recent enforcement activities and current trends in the SEC staff comment letters. We discuss the SEC's progress on rulemaking and other initiatives, including the changes in the accredited investor definition recommended by the SEC Advisory Committee on Small and Emerging Companies.
8 September 2016
Comment letter - SEC’s proposed amendment to the definition of smaller reporting company
In our comment letter, we offered a view on how the Commission should approach any potential changes to its accelerated filer definition. We also recommended conforming Rule 3 05 of Regulation S X with the proposed $100 million revenue limit for smaller reporting companies (i.e., require no more than two years of audited financial statements when an acquired business has annual revenue below $100 million).