Comment Letter - FASB’s proposal to incorporate certain SEC disclosure requirements into US GAAP

27 Jul 2019 PDF
Subject AccountingLink
Publications Comment Letters

Overview

In our comment letter, we support the FASB’s proposal to incorporate certain of the disclosure requirements referred by the SEC into US GAAP. We believe the FASB’s Codification should be the primary source of all note disclosure requirements. This approach would be more efficient for financial statement preparers and would promote timely periodic updates to the requirements. However, we have some concerns about aspects of the proposal, which we address in our comment letter. We also encourage the FASB staff to work with the SEC staff to eliminate the related disclosure requirements from Regulation S-X and Regulation S-K when this guidance goes into effect.

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