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Advocacy

Comment Letters

An important function of the NYSSCPA and its committees is participation in the public exposure process of regulators and standard-setters such as the FASB, PCAOB, IAASB, IRS, NY State Department of Taxation and Finance and many others. That participation is often accomplished through the drafting and submission of comment letters.

Comment letters are an effective mechanism to advocate for the profession and influence the adoption of sound policy and regulations in the areas of accounting, tax and finance. They are elemental to the Society's advocacy efforts and also serve to promote recognition and visibility by positioning the Society as a prominent and respected leader on accounting, tax and financial issues.

 

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2016 - Back to Top

 
2015 - Back to Top

 
2014 - Back to Top

9/29/14 - Comments on the IAASB proposed revisions to ISAs that are intended to address the practical challenges arising from the evolving aspects of disclosures.
9/26/14 - Comments to the AICPA Professional Ethics Division on their proposed revision to ET section 91 Applicability, and new Interpretation No. 101-20, “Breach of an Independence Interpretation,” under Rule 101, Independence, which provides guidance to members in public practice concerning a breach of an independence interpretation.
9/22/14 - Comments on a proposed accounting standards update, the objective of which is to simplify the measurement of inventory by measuring at the lower of cost and net realizable value and to more closely align the measurement of inventory in GAAP with the measurement of inventory in International Financial Reporting Standards. 
9/22/14 - Comments on a proposed accounting standards update, the objective of which is to reduce complexity, cost and time in the assessment of extraordinary events and to alleviate uncertainty surrounding extraordinary items.
8/14/14 - Comments to the International Ethics Standards Board for Accountants (IESBA) on proposed changes to certain provisions addressing non-assurance services for audit clients.
8/14/14 - Comments to the IRS Tax Exempt and Government Entities Division regarding Application for Extension of Time to File an Exempt Organization Return (Form 990) with recommendation that a single six-month extension be employed.
8/4/14 - Comments and suggestions to NYC HPD regarding appropriate form and language for the CPA's certification on Form J-10b.2 Affidavit by Certified Public Accountants and Statement by Certified Public Accountants Required by Section 421(a).
7/31/14 - Comments on a proposed accounting standards update, the objective of which is to provide guidance on when and how an acquired entity that is a business or nonprofit activity can apply pushdown accounting in its separate financial statements.
7/18/14 - Comments on this IAASB proposed revision to ISA 720 that is intended to bring enhanced clarity and consistency regarding the auditor’s responsibilities related to other information given the notable increase in the weight that users place on information in annual reports beyond the audited financial statements.
7/11/14 - Comments on a proposed statement of financial accounting concepts, the purpose of which is to provide the FASB with a framework for identifying information that could be appropriate for inclusion in notes to financial statements and relevant to the users of those statements.
7/9/14 - The Society believes believe preserving the cash basis method for pass-through entities, personal service corporations and farmers is critically important. Requiring a change to the accrual method would have a significant impact on job growth and the economy in New York State.
3/28/14 - Comments to the International Valuation Standards Council (IVSC) on their exposure draft of the first chapter of a rolling project to provide Illustrative Examples for many of the valuation concepts and principles discussed in the International Valuations Standards (IVS) Framework.
3/11/14 - NYSSCPA comments on proposed amendments to the "J-51 Rules" regarding professional certification of the cost of major capital improvements and related identified expenses by certified public accountants.
2/26/14 - Comments on a proposed accounting standards update, the objective of which is to reduce the diversity in practice related to classification by creditors of government-guaranteed residential mortgage loans entitling a creditor to the full unpaid principal balance of the loan upon foreclosure.
2/4/14 - The Public Company Accounting Oversight Board ("PCAOB") is reproposing amendments to its standards to improve transparency of public company audits requiring disclosure in the auditor's report of the name of the engagement partner and the names, locations, and extent of participation of other public accounting firms in the audit and the locations and extent of participation of other persons not employed by the auditor.
1/24/14 - The AICPA Professional Ethics Executive Committee (PEEC) is exposing for comment revised Interpretation No. 102-2, “Conflicts of interest for members in public practice,” and new Interpretation No. 102-7, “Conflicts of interest for members in business,” under Rule 102, Integrity and Objectivity which provide guidance to members in public practice and business concerning conflicts of interest.
1/21/14 - Comments to the SEC which is proposing new regulations on Crowdfunding under the Securities Act of 1933 and the Securities Exchange Act of 1934 to implement the requirements of Title III of the Jumpstart Our Business Startups Act that would prescribe rules governing the offer and sale of securities under new Section 4(a)(6) of the Securities Act of 1933.
1/2/14 - Comments on bipartisan legislation that would limit the Public Company Accounting Oversight Board (PCAOB) from requiring mandatory audit firm rotation for public companies and bring the lingering firm rotation debate in the U.S. to a swift conclusion.

 
2013 - Back to Top

12/19/13 - Comments on a proposed accounting standards update with proposed amendments that are intended to resolve the diverse accounting treatment of share-based payment awards that require a specific performance target to be achieved for employees to benefit.
12/19/13 - Comments on a proposed accounting standards update, the objective of which is to eliminate the use of different methods in practice and thereby reduce existing diversity surrounding the accounting for hybrid financial instruments issued in the form of a share under U.S. GAAP.
12/19/13 - Comments on a proposed accounting standards update, the objective of which is to improve financial reporting by reducing the cost and complexity associated with the incremental reporting requirements for a development stage entity.
12/18/13 - Comments on limitation on the use of the cash method of accounting for businesses as proposed by Chairman Baucus in his Cost Recovery and Accounting Discussion Draft (November 21, 2013).
12/10/13 - Comments to the Public Company Accounting Oversight Board on Release No. 2013-005, Proposed Auditing Standards – The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion; The Auditor's Responsibilities Regarding Other Information in Certain Documents Containing Audited Financial Statements and the Related Auditor's Report; and Related Amendments to PCAOB Standards.
11/19/13 - Comments on an exposure draft on expansion of the auditor's report and that includes proposed new ISA 701, Communicating Key Audit Matters in the Independent Auditor’s Report, and a number of proposed revised ISAs, including revisions to ISA 700, Forming an Opinion and Reporting on Financial Statements.
11/5/13 - Comments are being provided to AICPA on the proposed new definition of those charged with governance (paragraph .33 of ET section 92, Definitions [AICPA, Professional Standards]) because the AICPA Code of Professional Conduct refers to those charged with governance in a number of its provisions.
11/1/13 - Proposal of amendments to the Procedural Regulations and Personal Income Tax Regulations to implement certain of the recommendations of the Task Force on Regulation of Tax Return Preparers. 20 NYCRR section 158.12 and Part 2600.
10/9/13 - Comments on a proposed accounting standards update with proposed amendments that would permit a private company to elect not to apply variable interest entity (VIE) guidance for assessing whether it should consolidate a lessor entity under specified conditions.
9/26/13 - The Trust Services Principles and Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy presents criteria established by the Assurance Services Executive Committee (ASEC) of the AICPA for use by practitioners when providing attestation or consulting services to evaluate controls.
9/23/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance in U.S. GAAP about management’s responsibilities in evaluating an entity’s going concern uncertainties, and about the timing and content of related footnote disclosures.
9/16/13 - Comments on a proposed accounting standards update, the primary purposes of which are to amend the Master Glossary of the FASB Accounting Standards Codification® to include one definition of public business entity for use in U.S. GAAP and identify the types of business entities that would be excluded from the scope of the guide.
9/16/13 - Comments on a proposed accounting standards update the objective of which is to clarify when an in substance repossession or foreclosure occurs such that all or a portion of the loan should be derecognized and the real estate property recognized.
9/11/13 - Comments on a proposed accounting standards update that proposes changes to both lessee and lessor accounting and would supersede IAS 17, Leases (and related Interpretations), in International Financial Reporting Standards (IFRS) and the requirements in Topic 840, Leases (and related Subtopics) of the FASB accounting standards codification.
8/21/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance about an accounting alternative for the recognition, measurement, and disclosure of identifiable intangible assets acquired in a business combination.
8/21/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance about an accounting alternative for the subsequent measurement of goodwill.
8/21/13 - Comments on a proposed accounting standards update with amendments that would provide two simpler approaches, the combined instruments approach and the simplified hedge accounting approach, to account for swaps that are entered into for the purposes of economically converting variable-rate borrowing to fixed-rate borrowing.
8/13/13 - Comments regarding a revised AICPA Code of Professional Conduct (AICPA Code) for possible adoption by the AICPA Professional Ethics Executive Committee (PEEC). The PEEC is proposing to restructure and codify the AICPA Code so that members and other users can apply the rules and reach correct conclusions more easily and intuitively.
8/1/13 - Comments on a proposed accounting standards update that would address reporting issues under Subtopic 205-20 by changing the criteria for reporting discontinued operations and enhancing convergence of the FASB’s and the IASB’s reporting requirements for discontinued operations.
7/2/13 - Comments to the Public Company Accounting Oversight Board on Release 2012-004, a reproposal of a new auditing standard, Related Parties; amendments to certain PCAOB auditing standards regarding significant unusual transactions; and other amendments to PCAOB auditing standards. The reproposed standard would supersede the Board's existing auditing standard on related parties, AU sec. 334, Related Parties.
6/21/13 - This FASB Invitation to Comment was issued to solicit comments on a proposed guide for use by the FASB and the Private Company Council (PCC) in considering alternatives for private companies within U.S. generally accepted accounting principles (GAAP).
6/18/13 - The NYSSCPA sent a letter to certain members of New York's congressional delegation urging support for the bill which would, among other things, prevent the PCAOB from requiring mandatory audit firm rotation.
5/31/13 - The main objective in developing this proposal was to provide financial statement users with more decision-useful information about the expected credit losses on financial assets and other commitments to extend credit held by a reporting entity at each reporting date. These proposed amendments also would reduce complexity by replacing the numerous existing impairment models in current U.S. GAAP with a consistent measurement approach.
5/29/13 - Stakeholders have raised concerns that certain disclosure requirements in paragraph 820-10-50-2 of the FASB Accounting Standards Codification®, which was effective for nonpublic entities for annual periods beginning after December 15, 2011, would potentially provide proprietary information about nonpublic entities through the dissemination of their employee benefit plans’ financial statements on the regulator’s Web site. The amendments in this proposed Update would address those concerns by permitting an indefinite deferral of certain quantitative disclosure requirements in paragraph 820-10-50-2(bbb) for investments held by a nonpublic employee benefit plan in its plan sponsor’s own nonpublic entity equity securities.
5/28/13 - The Public Company Accounting Oversight Board ("PCAOB" or "Board") is proposing a framework for reorganizing the existing interim and PCAOB issued auditing standards into a topical structure with a single integrated numbering system. In addition, the PCAOB is proposing certain conforming amendments to Rule 3101, Certain Terms Used in Auditing and Related Professional Practice Standards, and Rule 3200T, Interim Auditing Standards. The Board also is proposing certain related amendments to the PCAOB auditing standards and proposing to rescind certain interim auditing standards that the Board believes are no longer necessary under the proposed reorganization.
5/14/13 - Comments on a proposed accounting standards update, the objective of which is is to provide financial statement users with more decision-useful information about an entity’s involvement in financial instruments, while reducing the complexity in accounting for those instruments.
4/22/13 - Comments on a proposed accounting standards update, the objective of which is to address whether the Fed Funds Effective Swap Rate (OIS) should be included as a U.S. benchmark interest rate for hedge accounting purposes, in addition to UST and LIBOR.
4/22/13 - Comments on a proposed accounting standards update, the objective of which is to eliminate the diversity in practice in the presentation of unrecognized tax benefits.
3/19/13 - Comments on a proposed accounting standards update, the objective of which is to improve the existing accounting and disclosure guidance on repurchase agreements and other transactions involving a transfer and a forward agreement to repurchase the transferred assets at a fixed price from the transferee.
3/18/13 - NYSSCPA response to a request for comments by the International Auditing and Assurance Standards Board (IAASB) on proposed ISA 720 (Revised), The Auditor’s Responsibilities Relating to Other Information in Documents Containing or Accompanying Audited Financial Statements and the Auditor’s Report Thereon. The proposals extend the scope of the extant standard and the auditor’s responsibilities and include suggested auditor reporting responsibilities.
3/14/13 - A formal letter in opposition to legislative leaders regarding amendments added to the 2013 New York State budget bills that removed the requirements for annual internal audits.
2/27/13 - Comments on proposed regulations (REG-130507-11) providing guidance for the net investment tax imposed under section 1411. Section 1411 was added by the Health Care and Education Reconciliation Act of 2010, effective for tax years beginning after December 31, 2012, and imposes a 3.8% tax on “net investment income” of higher income individuals and certain estates and trusts to fund the Act.
1/14/13 - The Professional Ethics Executive Committee (PEEC) is exposing for comment a proposed revision to Interpretation No. 102-4, “Subordination of Judgment by a Member” under Rule 102, Integrity and Objectivity (AICPA, Professional Standards, ET sec. 102 par.05), of the AICPA Code of Professional Conduct (AICPA Code). PEEC believes that a member should not be precluded from resigning from an organization at any time. The interpretation provides that safeguards should be applied to situations involving a difference of opinion with a supervisor so that a member does not subordinate his or her judgment.
1/14/13 - Comment to the AICPA on its Exposure Draft of a Proposed Statement on Standards for Accounting and Review Services – the Exposure Draft represents the redrafting of the paragraphs of SSARS No. 19 to apply the Accounting and Review Services Committee’s (ARSC’s) clarity drafting conventions and to include changes from existing standards in the following sections in the codified SSARSs: AR section 90, Review of Financial Statements (Revised) and AR section 95, Review of Financial Statements—Special Considerations. ARSC is seeking comments specifically on changes resulting from applying the clarity drafting conventions and their effect on the content of the proposed SSARSs.

 
2012 - Back to Top

12/18/12 - NYSSCPA proposed independent auditor’s report for purposes of NYC Form TC309, Accountant's Certification, to conform with the Clarity Auditing Standards issued by the AICPA effective for audits of entities with a fiscal year ending on or after December 15, 2012.
12/17/12 - Response to an invitation to comment on FASB Discussion Paper – Disclosure Framework. The objective and primary focus of the FASB project is to improve the effectiveness of disclosures in notes to financial statements by clearly communicating the information that is most important to users of each entity’s financial statements.
12/3/12 - Comments on the Professional Ethics Executive Committee (PEEC) September 19, 2012 Omnibus Exposure Draft - Interpretation and Definitions. Proposed are revisions to the definitions of practice of public accounting and professional services as well as deletion of the definition holding out from the AICPA’s Code of Professional Conduct.
12/3/12 - Comments to ISACA (Information Systems Audit and Control Association) on an exposure draft of proposed standards for an information technology assurance framework.
11/8/12 - Response to an invitation to comment (ITC) on FASB Discussion Paper–Private Company Decision-Making Framework, A Framework for Evaluating Financial Accounting and Reporting Guidance for Private Companies. The purpose of the ITC is to gather input from stakeholders about the appropriateness, completeness, and cost effectiveness of the draft private company (nonpublic business entity) decision-making framework. 
11/7/12 - Letter requesting an extension of the CPE reporting year by four weeks in light of the devastation wrought by Hurricane Sandy, and noting that the state took similar action after Hurricane Irene. 

10/19/12 - Comments on a proposed accounting standards update, the objective of which is to improve the presentation of reclassifications out of accumulated other comprehensive income by disclosing their effect on the respective line items in net income if the item being reclassified is required under U.S. GAAP to be reclassified in its entirety to net income.

10/18/12 - The Business Valuation Committee of the New York State Society of Certified Public Accountants (NYSSBV) has reviewed the Second Exposure Draft of Proposed Changes for the 2014-15 Edition of the Uniform Standards of Professional Appraisal Practice (the “Exposure Draft”) and has summarized its comments.

10/16/12 - Comments on a proposed accounting standards update, the objective of which is to provide users of financial statements with more decision-useful information about entity-level exposures to liquidity risk and interest rate risk.

10/2/12 - NYSSCPA response to the International Auditing and Assurance Standards Board (IAASB) Invitation to Comment: Improving the Auditor’s Report (ITC). The ITC sets out the IAASB’s indicative direction proposed for the future of the auditor’s report.

9/26/12 - NYSSCPA President Gail M. Kinsella sent a letter to the New York State members of the U.S. Senate Finance Committee      (Senator Charles Schumer D-NY) and the U. S. House Ways and Means Committee (Congressmen Joseph Crowley D-NY,  Charles B. Rangel D-NY, Tom Reed R-NY) proposing targeted, short-term exceptions to the 10% additional tax levied on early withdrawals from individual retirement plans to alleviate economic hardships faced by taxpayers as a result of the economic crisis. (The letter linked here is to Senator Schumer).

9/14/12 - Comments on a proposed accounting standards update, the objective of which is to provide guidance for the recognition, measurement, and disclosure of obligations resulting from joint and several liability arrangements for which the total amount under the arrangement is fixed at the reporting date, except for obligations addressed within existing guidance in U.S. GAAP.

9/5/12 - Comments on an exposure draft of the AICPA Assurance Services Executive Committee (ASEC), Emerging Assurance Technologies Task Force, entitled Audit Data Standard. ASEC believes that audit data standards would contribute to the efficiency and effectiveness of the audit process.

9/4/12 - Comments regarding temporary and proposed regulations that provide guidance on the estate and gift tax applicable exclusion amount, in general, as well as on the applicable requirements for electing portability of a deceased spousal unused exclusion (DSUE) amount to the surviving spouse and on the applicable rules for the surviving spouse’s use of this DSUE amount.

8/27/12 - Comments on the Professional Ethics Executive Committee (PEEC) June 29, 2012 Omnibus Exposure Draft - Proposed Revisions to Interpretation 101-3, Proposed New Interpretations 501-11 and 502-6 and Proposed Deletion of Ethics Rulings.

8/27/12 - Comments on an exposure draft of Proposed Statements on Standards for Accounting and Review Services (SSARSs) – Association With Unaudited Financial Statements, Compilation of Financial Statements, and Compilation of Financial Statements—Special Considerations. The proposed SSARSs would supersede paragraphs 1.05–.06 and 2.01–.64 of SSARS No. 19, SSARS No. 13, SSARS No. 3 and SSARS No. 6, and represent a redrafting to apply the AICPA Accounting and Review Services Committee’s (ARSC’s) clarity drafting conventions.

8/16/12 – NYSSCPA President Gail M. Kinsella sent a letter to United States Senator Kirsten Gillibrand (D-NY) on August 16 urging her to co-sponsor Senate Bill 1232. The bill would modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) to exclude appraisers of Employee Stock Ownership Plans (ESOPs). 

7/10/12 - NYSSCPA President Gail M. Kinsella sent a letter to United States Senator Charles Schumer (D-NY) on July 10 urging him to co-sponsor Senate Bill 845. The bill would allow partnerships, corporations, trusts, estates, and individuals to better submit timely, accurate returns and reduce the need for extended and amended returns.

5/17/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2012-001, a proposed standard that would supersede the PCAOB’s interim standard AU sec. 334, Related Parties. The proposed standard and amendments address evaluation of a company's identification of related party transactions, identifying and evaluating a company's accounting and disclosure of significant unusual transactions and obtaining an understanding of a company's financial relationships and transactions with executive officers sufficient to identify risks of material misstatement.

5/3/12 - The NYSSCPA International Taxation Committee offered comments to the Internal Revenue Service as it identified the reporting of foreign retirement plans, in particular, Canadian registered retirement savings plans and Canadian registered retirement funds (together referred to as “RRSPs”), held by U.S. persons, as a significant issue that deserves additional attention from Treasury and the IRS in order to lend clarity to their tax treatment.

4/19/12 - Response to a request for comments regarding when (and under what circumstances) transfers by a trustee of all or a portion of the principal of an irrevocable trust (Distributing Trust) to another irrevocable trust (Receiving Trust), that result in a change in the beneficial interests in the trust, are not subject to income, gift, estate, or generation-skipping transfer taxes.

3/19/12 - Comments regarding IRB 2012-8, February 21, 2012, REG-130302-10, Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations Reporting of Specified Foreign Financial Assets (T.D. 9567). Temporary regulations relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest.

3/7/12 - Comments on a proposed accounting standards update (a joint project of FASB and IASB) to clarify the principles for recognizing revenue and to develop a common revenue standard for U.S. GAAP and IFRSs.

2/28/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-008 proposing transitional amendments to AU sec. 380, Communication With Audit Committees, and reproposing an auditing standard, Communications with Audit Committees, that would supersede the Board's interim standards AU sec. 380 and AU sec. 310, Appointment of the Independent Auditor, and related amendments to PCAOB standards.

2/10/12 - Comments on a proposed accounting standards update to address the diversity in practice related to entities that invest in real estate. The amendments in this proposed Update would provide accounting guidance for an entity that meets the criteria to be an investment property entity. The proposed amendments also would introduce additional presentation and disclosure requirements for an investment property entity.

2/10/12 - Comments on a proposed accounting standards update of Topic 810, Consolidation. The proposed amendments in this Update would affect all reporting entities that are required to evaluate whether they should consolidate another entity. The proposed amendments are expected to most significantly affect the financial reporting of entities that are involved with variable interest entities.

2/10/12 - Comments on a proposed accounting standards update of Topic 946, Financial Services—Investment Companies. The amendments in this proposed Update would affect the scope, measurement, presentation, and disclosure requirements for investment companies in U.S. generally accepted accounting principles (GAAP).

1/25/12 - Comments on an exposure draft of a proposed statement on auditing standards (SAS). The proposed SAS would supersede SAS No. 59, The Auditor's Consideration of an Entity's Ability to Continue as a Going Concern, as amended (AICPA, Professional Standards, AU sec. 341 and AU-C sec. 570), and represents the redrafting of SAS No. 59 to apply the Auditing Standards Board’s clarity drafting conventions.

1/19/12 - The Professional Ethics Executive Committee (PEEC) is exposing for comment two new interpretations under Rule 505, Form of Organization and Name (AICPA, Professional Standards, ET sec. 505 par. .01). Proposed Interpretation No. 505-4, “Misleading Firm Names,” and proposed Interpretation No. 505-5, “Use of a Common Brand Name in Firm Name,” provide guidance on when firm names would be considered misleading. Also, The PEEC is recommending Ethics Ruling No. 134, “Association of Accountants Not Partners,” of ET section 591, Ethics Rulings on Other Responsibilities and Practices (AICPA, Professional Standards, ET sec. 591, par. .267), be deleted because the guidance contained in proposed Interpretation No. 505-4, “Misleading Firm Names,” would provide members with guidance on misleading firm names.

1/4/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-007, proposed amendments to PCAOB standards that would: (1) require registered public accounting firms to disclose the name of the engagement partner, (2) amend the Annual Report Form to require firms to disclose the name of the engagement partner for each audit report already required to be reported on the form, and (3) require disclosure in the audit report of other independent public accounting firms and other persons that took part in the audit.

 
2011 - Back to Top

12/13/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-006, a concept release to solicit public comment on ways that auditor independence, objectivity and professional skepticism could be enhanced, including the possible approach of mandatory audit firm rotation.

12/12/11 - The NYSSCPA President’s letter to the FAF acknowledging the need to improve the financial reporting of private companies calling for an autonomous standard-setting body to implement differential standards for private companies that is not subject to FASB ratification.

12/6/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to amend the definition of “monetary instrument'' in the Bank Secrecy Act (``BSA'') regulations for purposes of the international transport of currency and monetary instrument reporting requirement to include tangible prepaid access devices.

11/14/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to require electronic filing of Bank Secrecy Act Reports.

10/21/11 - Response to IRS Notice 2011-82 inviting public comments on specific issues which have been identified for consideration in proposed regulations to be issued under section 2010(c).

9/27/11 - Comments on a proposed accounting standards update, the objective of which is to resolve the diversity in practice about whether the guidance in Subtopic 360-20 applies to a parent that ceases to have a controlling financial interest in a subsidiary that is in substance real estate as a result of default on the subsidiary’s nonrecourse debt.

9/27/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-003, a concept release to solicit public comment on the potential direction of a proposed standard-setting project on the content and form of reports on audited financial statements, specifically potential changes to the auditor's reporting model based on concerns of investors and other financial statement users.

9/14/11 - NYSSCPA response to a request by the International Auditing and Assurance Standards Board (IAASB) for comments on a consultation paper that seeks to determine whether there are common views among users of audited financial statements and other stakeholders about the usefulness of auditor reporting.

7/28/11 - Comments on recommendations made by the Blue-Ribbon Panel on Private Company Financial Reporting to the Financial Accounting Foundation regarding differential standards and a separate standard-setting entity for private companies.

7/28/11 - Comments to the Securities and Exchange Commission on an SEC Staff Paper: Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers – Exploring a Possible Method of Incorporation (May 26, 2011).

7/1/11 - Comments to the IRS in response to IRS Notice 2011-48 inviting public comments on the content and administration of the registered tax return preparer competency examination.

6/30/11 - Letter to NYS Governor Andrew M. Cuomo recommending the signing into law of bill A.4881-B/S.2628-A to grant cross-border practice mobility in accordance with Section 23 of the Model Uniform Accountancy Act.

6/6/11 - Comments on a proposed accounting standards update, the objective of which is to simplify how an entity is required to test goodwill for impairment by permitting a qualitative assessment.

5/31/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on a discussion paper that explores issues and perspectives regarding financial statement disclosures and auditing disclosures in a financial statement audit.

5/31/11 - Comments to the IRS indicating circumstances in which additional guidance might be beneficial with respect regulations on basis reporting by securities brokers and basis determination for stock (Final Regulations 1.1012-1(c)(10), 1.1012-1(e)(12), 1.6045A-1(d), 1.6045B-1(g)).

5/23/11 - Recommendations to the IRS to improve tax reporting, specifically, recommendations on changes to certain tax filing due dates.

5/23/11 - Comments to the IRS regarding the effect on an S corporation shareholder’s stock basis of prior year losses that were not deductible because of the basis limitation on deductibility of losses.

4/27/11 - Comments on a proposed accounting standards update addressing the differences in the offsetting (netting) requirements in U.S. GAAP and IFRSs.

4/27/11 - Response to an invitation to comment, issued by the FASB and IASB, on their discussion paper considering how best to improve and simplify standards for financial reporting of financial instruments, and, at the same time, provide users with clearer and more complete information.

4/4/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on the proposed IAASB Strategy and Work Program for 2012 – 2014.

4/1/11 - Comments to the FASB on this Supplementary Document, issued by the FASB as a step preceding the development of an Exposure Draft of a proposed Accounting Standards Update. This supplementary document presents an impairment model that the FASB and IASB believe will enable them to satisfy at least part of their individual objectives for impairment accounting while achieving a common solution to impairment.

2/16/11 - Letter to New York City Department of Finance Commissioner Frankel requesting resumption of the Tax Representatives and Practitioners Program (TaxRAPP), noting its benefit to both practitioners and the department.

2/11/11 - Comments on proposals relating to International Auditing Practice Statements (IAPSs) including withdrawal of existing IAPSs, clarification of the status and authority of new IAPSs, proposed amendments to the Preface to the International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements, and Proposed International Auditing Practice Statement IAPSs 1000, Special Considerations in Auditing Complex Financial Instruments.

2/7/11 - Letter to NYS Governor Andrew M. Cuomo recommending the continuation of the Office of the New York State Taxpayer Rights Advocate, that its role be codified, and suggestions as to its term, reporting, and other aspects.

1/31/11 - Comments to the AICPA on a Proposed Revised Statement on Auditing Standards, Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country. This proposed revised SAS would supersede SAS No. 51, Reporting on Financial Statements Prepared for Use in Other Countries (AICPA, Professional Standards, vol. 1, AU sec. 534).

1/12/11 - Comments to the FASB on a Proposed Accounting Standards Update – Transfers and Servicing (Topic 860) Reconsideration of Effective Control for Repurchase Agreements. The objective of the proposed update is to improve the accounting for repurchase agreements (repos) and other agreements that both entitle and obligate a transferor to repurchase or redeem financial assets before their maturity.

 
2010 - Back to Top

12/15/10 – Comments to the FASB on a Proposed Accounting Standards Update – Leases (Topic 840), a joint project of the FASB and IASB to develop a new approach to lease accounting that would ensure that assets and liabilities arising under leases are recognized in the statement of financial position. 

10/22/10 - Comments to the FASB on a Proposed Accounting Standards Update – Revenue Recognition (Topic 605) Revenue from Contracts with Customers. The proposed guidance, part of joint FASB and IASB effort to clarify revenue recognition principles, specifies the principles that an entity would apply to report information about revenue and cash flows arising from its contracts to provide goods or services to customers.

10/8/10 - Comments on an exposure draft of a proposed statement on auditing standards. The proposed SAS would supersede paragraph 5 of SAS No. 116, Interim Financial Information (AICPA, Professional Standards, vol. 1, AU sec. 722).

9/30/10 - Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments (Topic 825) and Derivatives and Hedging (Topic 815): Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. The objective of the proposed Update is to provide financial statement users with a more timely and representative depiction of an entity’s involvement in financial instruments, while reducing the complexity in the accounting.

9/30/10 - Comments to the FASB on a Proposed Accounting Standards Update – Comprehensive Income (Topic 220): Statement of Comprehensive Income. The amendments in this proposed Update would require that all components of comprehensive income be reported in a continuous financial statement that displays the components of net income and the components of other comprehensive income within comprehensive income.

9/28/10 - Letter to the NYS Congressional Delegation requesting action to repeal section 9006, which imposes unreasonably burdensome Form 1099 reporting requirements on all business taxpayers, particularly on small businesses.

9/28/10 - Comments to the IRS regarding new requirements with respect to the reporting of payments made in the course of a payor’s trade or business. The new requirements are in IRC Section 6041, which was amended by section 9006 of the Patient Protection and Affordable Care Act of 2010. Very generally, the amendments expand existing information reporting requirements (generally on form 1099) to apply to payments made to corporations and to include certain payments of gross proceeds and with respect to property.

9/13/10 – Comments to the Public Company Accounting Oversight Board on Release No. 2010-003 (Docket No. 028), a proposed auditing standard which would supersede the Board's standard, AU section 330, The Confirmation Process, and related amendments to the Board's auditing standards.

9/13/10 – Comments to the New York State Board for Public Accountancy of the New York State Education Department on proposed new Section 70.10 of the Regulations of the Commissioner of Education to establish a mandatory quality review program for the profession of public accountancy.

9/9/10 - Comments to the SEC on interactive data to improve financial reporting with observations obtained from the implementation of the Extensible Business Reporting Language (XBRL).

9/7/10 - Comments to the FASB on a Proposed Accounting Standards Update – Fair Value Measurements and Disclosures (Topic 820): Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs. This proposed Update is a result of the continuing efforts of the FASB and the IASB to develop common requirements for measuring fair value and for disclosing information about fair value measurements.
 

9/7/10 - Comments to the FASB on a Proposed Accounting Standards Update – Plan Accounting—Defined Contribution Pension Plans (Topic 962): Reporting Loans to Participants by Defined Contribution Pension Plans. The objective of the proposed Update is to clarify how loans to participants should be classified and measured by defined contribution pension benefit plans.
 

8/31/10 – Comments to the AICPA’s Peer Review Board on their exposure draft of proposed revisions to the standards for performing and reporting on peer reviews, specifically the process used to evaluate quality control materials (QCM) and continuing professional education (CPE) programs and guidance and independence concerns for those involved in the development and maintenance of QCM or CPE programs.
 

8/27/10 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposed revisions to the Bank Secrecy Act regulations applicable to Money Services Businesses with regard to stored value or prepaid access payment methods.

 

 

8/20/10 - Comments to the FASB on a Proposed Accounting Standards Update: Receivables (Topic 310) – Disclosure of Certain Loss Contingencies. To improve adequacy and timeliness of information in assessing the likelihood, timing, and magnitude of future cash outflows associated with loss contingencies

 

  • Comments to the IASB on an Exposure Draft – Financial Instruments: Amortised Cost and Impairment

    6/28/10 - Comments on an IASB exposure draft representing the second phase of a project to replace IAS 39 Financial Instruments: Recognition and Measurement, the stated objective of which is to improve the decision-usefulness of financial statements for users by improving amortised cost measurement, in particular the transparency of provisions for losses on loans and for the credit quality of financial assets.

    4/27/10 – Comments on an exposure draft of a proposed statement on auditing standards. The proposed SAS would supersede SAS No. 73, Using the Work of a Specialist (AICPA, Professional Standards, vol. 1, AU sec. 336) and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    8/7/09 - Comments on IASB's exposure draft of proposals to improve the derecognition requirements for financial instruments in IAS 39 and enhance disclosure requirements regarding an entity’s exposure to the risks of transferred financial assets.

    7/17/09 – Comments on an exposure draft of a proposed statement on auditing standards on subsequent events. This proposed SAS would supersede SAS Nos. 1 and 58 and AU sections 530, 560 and 561, and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    7/2/09 – Comments on FASB's proposed FSP 157-g that would amend FASB Statement No. 157, Fair Value Measurements, to provide application guidance for estimating the fair value of investments in investment companies that have calculated net asset value per share in accordance with the AICPA Audit and Accounting Guide, Investment Companies.

    6/3/09 – Comments on an exposure draft of a proposed statement on auditing standards on initial audit engagements, including reaudits – opening balances. This proposed SAS would supersede SAS No. 84, Communications Between Predecessor and Successor Auditors and represents a redrafting of SAS No. 84 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on a Proposed Statement on Auditing Standards – Consideration of Laws and Regulations in an Audit of Financial Statements

    6/3/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede SAS No. 54, Illegal Acts by Clients and represents the inclusion of comments by the Auditing Standards Board’s clarity drafting conventions and convergence with International Standards on Auditing.

    5/29/09 – Comments on an exposure draft of a proposed statement on auditing standards on audit sampling. This proposed SAS represents the redrafting of SAS No. 39, Audit Sampling to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA and CICA on Exposure Draft - Generally Accepted Privacy Principles

    5/29/09 – Comments to the AICPA and Canadian Institute of Chartered Accountants (CICA) on their exposure draft of generally accepted privacy principles designed to be used as an operational framework to manage privacy risks.

    2/12/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede Statement on Auditing Standards No. 70, Service Organizations, which contains guidance for auditors auditing the financial statements of entities that use a service organization and for auditors reporting on controls at a service organization.

    2/11/09 – Comments to the Public Company Accounting Oversight Board on Release No. 2008-006, specifically addressing Appendix 4, The Auditor's Responses to the Risks of Material Misstatement, page A4–13–37.

9/29/08 - NYSSCPA response to FASB’s Invitation to Comment –Preliminary Views, Conceptual Framework for Financial Reporting: The Reporting Entity.

    7/2/08 – Comments on the proposed Statement on Auditing Standards (SAS) No. 114 (Redrafted), The Auditor’s Communication With Those Charged with Governance, that would supersede existing SAS No. 114. The proposed SAS represents the redrafting of SAS No. 114 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on Proposed Statement on Auditing Standards No. 103 (Redrafted), Audit Documentation

    7/2/08 – Comments on the proposed Statement on Auditing Standards (SAS) No. 103 (Redrafted), Audit Documentation, that would supersede existing SAS No. 103. The proposed SAS represents the redrafting of SAS No. 103 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    6/30/08 – Comments to the Governmental Accounting Standards Board on their exposure draft of fund balance reporting and governmental fund type definitions.

    12/28/07– Comments on proposed FASB Staff Position (FSP) FAS 157-a – Application of FASB Statement No. 157 to FASB Statement No. 13 and its related interpretive accounting pronouncements that address leasing transactions (issued 11/28/07).

  • Comments to AICPA on Improving the Uniform CPA Examination

    9/21/07 – Comments to the Securities and Exchange Commission on Release No. 33-8818 – Acceptance from Foreign Private Issuers of Financial Statements Prepared in Accordance with International Financial Reporting Standards without Reconciliation to U.S. GAAP.

    11/14/06 – Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their Exposure Draft - Omnibus Proposal of Professional Ethics Division Interpretations and Rulings dated September 8, 2006. Comments are on the Proposed Deletion of Rulings Under Rule 101, and Proposed Revision to Interpretation 101-3 under Rule 101: Performance of Nonattest Services: Forensic Accounting Services and Tax Compliance Services.

  • Comments to FASB on Preliminary Views - Conceptual Framework for Financial Reporting

    8/3/06 – Comments to GASB on its preliminary views document regarding the accounting and financial reporting for derivatives in government-wide and fund financial statements.

    1/27/06 – Comments to AICPA Professional Ethics Executive Committee on Proposed Omnibus Proposal: Proposed Interpretation 101-17, Performance of Client Advocacy Services, Fact Witness Testimony, and Forensic Accounting Services, Under Rule 101, Independence, dated September 15, 2005

1/13/06 – Response to the Committee of Sponsoring Organizations’ (COSO) request for comment on their exposure draft of proposed Guidance for Smaller Public Companies Reporting on Internal Control over Financial Reporting.

 
2005 - Back to Top

    11/2/05 – Comments to the AICPA Auditing Standards Board on the ASB’s Exposure Draft of a proposed Statement on Auditing Standards entitled “Communication of Internal Control Related Matters Noted in an Audit.” The proposed standard is intended to strengthen the communication of internal control related matters for non-issuer entities.

    3/4/05 – Response to request from the NY State CFR Interagency Committee for advice on options for the reporting of sales of management services on the consolidated fiscal report.

  • Comments on PCAOB Release No. 2004-015 – Proposed Ethics and Independence Rules

    2/22/05 – Comments on PCAOB Release No. 2004-015 – Proposed Ethics and Independence Rules concerning Independence, Tax Services, and Contingent Fees.

 
2004 - Back to Top

    1/20/04 Society’s comments to the PCAOB regarding its proposed rules on audit documentation and amendment to interim auditing standards, and suggestion to incorporate a glossary of terms.

  • Recommendations on NYC Form TC 201

 
2003 - Back to Top

    11/21/03 - Comments on the Public Company Accounting Oversight Board’s exposure draft of proposed rules that would integrate the audits of internal control over financial reporting with the audits of financial statements.

    9/15/03 - Society’s response to Treasury’s request for comments on proposed regulations relating to the assumption of and definition of liabilities under section 752 of the Internal Revenue Code.

    8/1/03 - Society’s respone to the AICPA’s request for comments regarding the recently issued exposure draft on proposed revisions to the AICPA Standards for Performing and Reporting on Peer Reviews.

  • Comments on AICPA Professional Ethics Executive Committee Exposure Draft

    5/31/03 - Comments on the AICPA PEEC Exposure Draft: Omnibus Proposal of Professional Ethics Division Interpretations and Rulings, March 19, 2003

  • Comments on Tax Simplification

    5/27/03 - NYSSCPA strongly urges Congress to address simplification issues either in IRS regulations or in future legislation.

    A specially appointed NYSSCPA task force identifies the more egregious areas of the Internal Revenue Code that are eligible for simplification, outlines why they are complex and offers solutions to assure proper compliance.

    4/23/03 - Comments on Attorney General Eliot Spitzer's proposed legislation for governing not-for-profit organizations in New York State.

    1/17/03 - Specific comments on this proposed International Auditing Practice Statement (IAPS) of the International Federation of Accountants (IFAC) for Reporting on Compliance with International Financial Reporting Standards.

    7/9/02 - Society comments on a FASB exposure draft dealing with the accounting for derivatives and hedging.

    7/9/02 - Society comments on an ASB exposure draft dealing with one of the most important issues that the O'Malley Panel identified for auditors, the consideration of fraud in a financial statement audit.

    6/26/02 - Society comments on the proposed amendment to SAS 50, which would prohibit an accountant from providing a written report on the application of accounting principles not involving facts and circumstances of a specific entitiy (hypothetical trasnsactions).

     

 
Comments to the AICPA - Back to Top

9/26/14 - Comments to the AICPA Professional Ethics Division on their proposed revision to ET section 91 Applicability, and new Interpretation No. 101-20, “Breach of an Independence Interpretation,” under Rule 101, Independence, which provides guidance to members in public practice concerning a breach of an independence interpretation.
1/24/14 - The AICPA Professional Ethics Executive Committee (PEEC) is exposing for comment revised Interpretation No. 102-2, “Conflicts of interest for members in public practice,” and new Interpretation No. 102-7, “Conflicts of interest for members in business,” under Rule 102, Integrity and Objectivity which provide guidance to members in public practice and business concerning conflicts of interest.
11/5/13 - Comments are being provided to AICPA on the proposed new definition of those charged with governance (paragraph .33 of ET section 92, Definitions [AICPA, Professional Standards]) because the AICPA Code of Professional Conduct refers to those charged with governance in a number of its provisions.
9/26/13 - The Trust Services Principles and Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy presents criteria established by the Assurance Services Executive Committee (ASEC) of the AICPA for use by practitioners when providing attestation or consulting services to evaluate controls.
8/13/13 - Comments regarding a revised AICPA Code of Professional Conduct (AICPA Code) for possible adoption by the AICPA Professional Ethics Executive Committee (PEEC). The PEEC is proposing to restructure and codify the AICPA Code so that members and other users can apply the rules and reach correct conclusions more easily and intuitively.
1/14/13 - The Professional Ethics Executive Committee (PEEC) is exposing for comment a proposed revision to Interpretation No. 102-4, “Subordination of Judgment by a Member” under Rule 102, Integrity and Objectivity (AICPA, Professional Standards, ET sec. 102 par.05), of the AICPA Code of Professional Conduct (AICPA Code). PEEC believes that a member should not be precluded from resigning from an organization at any time. The interpretation provides that safeguards should be applied to situations involving a difference of opinion with a supervisor so that a member does not subordinate his or her judgment.
1/14/13 - Comment to the AICPA on its Exposure Draft of a Proposed Statement on Standards for Accounting and Review Services – the Exposure Draft represents the redrafting of the paragraphs of SSARS No. 19 to apply the Accounting and Review Services Committee’s (ARSC’s) clarity drafting conventions and to include changes from existing standards in the following sections in the codified SSARSs: AR section 90, Review of Financial Statements (Revised) and AR section 95, Review of Financial Statements—Special Considerations. ARSC is seeking comments specifically on changes resulting from applying the clarity drafting conventions and their effect on the content of the proposed SSARSs.
12/3/12 - Comments on the Professional Ethics Executive Committee (PEEC) September 19, 2012 Omnibus Exposure Draft - Interpretation and Definitions. Proposed are revisions to the definitions of practice of public accounting and professional services as well as deletion of the definition holding out from the AICPA’s Code of Professional Conduct.

9/5/12 - Comments on an exposure draft of the AICPA Assurance Services Executive Committee (ASEC), Emerging Assurance Technologies Task Force, entitled Audit Data Standard. ASEC believes that audit data standards would contribute to the efficiency and effectiveness of the audit process.

8/27/12 - Comments on the Professional Ethics Executive Committee (PEEC) June 29, 2012 Omnibus Exposure Draft - Proposed Revisions to Interpretation 101-3, Proposed New Interpretations 501-11 and 502-6 and Proposed Deletion of Ethics Rulings.

8/27/12 - Comments on an exposure draft of Proposed Statements on Standards for Accounting and Review Services (SSARSs) – Association With Unaudited Financial Statements, Compilation of Financial Statements, and Compilation of Financial Statements—Special Considerations. The proposed SSARSs would supersede paragraphs 1.05–.06 and 2.01–.64 of SSARS No. 19, SSARS No. 13, SSARS No. 3 and SSARS No. 6, and represent a redrafting to apply the AICPA Accounting and Review Services Committee’s (ARSC’s) clarity drafting conventions.

1/31/11 - Comments to the AICPA on a Proposed Revised Statement on Auditing Standards, Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country. This proposed revised SAS would supersede SAS No. 51, Reporting on Financial Statements Prepared for Use in Other Countries (AICPA, Professional Standards, vol. 1, AU sec. 534).

1/25/12 - Comments on an exposure draft of a proposed statement on auditing standards (SAS). The proposed SAS would supersede SAS No. 59, The Auditor's Consideration of an Entity's Ability to Continue as a Going Concern, as amended (AICPA, Professional Standards, AU sec. 341 and AU-C sec. 570), and represents the redrafting of SAS No. 59 to apply the Auditing Standards Board’s clarity drafting conventions.

1/19/12 - The Professional Ethics Executive Committee (PEEC) is exposing for comment two new interpretations under Rule 505, Form of Organization and Name (AICPA, Professional Standards, ET sec. 505 par. .01). Proposed Interpretation No. 505-4, “Misleading Firm Names,” and proposed Interpretation No. 505-5, “Use of a Common Brand Name in Firm Name,” provide guidance on when firm names would be considered misleading. Also, The PEEC is recommending Ethics Ruling No. 134, “Association of Accountants Not Partners,” of ET section 591, Ethics Rulings on Other Responsibilities and Practices (AICPA, Professional Standards, ET sec. 591, par. .267), be deleted because the guidance contained in proposed Interpretation No. 505-4, “Misleading Firm Names,” would provide members with guidance on misleading firm names.

10/8/10 - Comments on an exposure draft of a proposed statement on auditing standards. The proposed SAS would supersede paragraph 5 of SAS No. 116, Interim Financial Information (AICPA, Professional Standards, vol. 1, AU sec. 722).

8/31/10 – Comments to the AICPA’s Peer Review Board on their exposure draft of proposed revisions to the standards for performing and reporting on peer reviews, specifically the process used to evaluate quality control materials (QCM) and continuing professional education (CPE) programs and guidance and independence concerns for those involved in the development and maintenance of QCM or CPE programs 

    4/27/10 – Comments on an exposure draft of a proposed statement on auditing standards. The proposed SAS would supersede SAS No. 73, Using the Work of a Specialist (AICPA, Professional Standards, vol. 1, AU sec. 336) and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    12/3/09 - Comments on an exposure draft of a proposed statement on auditing standards that would supersede SAS No. 57, Auditing Accounting Estimates and Auditing Fair Value Measurements and Disclosures and SAS No. 101, Auditing Fair Value Measurements and Disclosures and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on a Proposed Statement on Auditing Standards - External Confirmations

8/25/09 – Comments on an exposure draft of a proposed statement on auditing standards on external confirmations. This proposed SAS would supersede SAS No. 67, and represents a redrafting to apply the Auditing Standards Board's clarity drafting conventions and to converge with International Standards

    7/17/09 – Comments on an exposure draft of a proposed statement on auditing standards on subsequent events. This proposed SAS would supersede SAS Nos. 1 and 58 and AU sections 530, 560 and 561, and represents a redrafting to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    6/3/09 – Comments on an exposure draft of a proposed statement on auditing standards on initial audit engagements, including reaudits – opening balances. This proposed SAS would supersede SAS No. 84, Communications Between Predecessor and Successor Auditors and represents a redrafting of SAS No. 84 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on a Proposed Statement on Auditing Standards – Consideration of Laws and Regulations in an Audit of Financial Statements

    6/3/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede SAS No. 54, Illegal Acts by Clients and represents the inclusion of comments by the Auditing Standards Board’s clarity drafting conventions and convergence with International Standards on Auditing.

    5/29/09 – Comments on an exposure draft of a proposed statement on auditing standards on audit sampling. This proposed SAS represents the redrafting of SAS No. 39, Audit Sampling to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA and CICA on Exposure Draft - Generally Accepted Privacy Principles

    5/29/09 – Comments to the AICPA and Canadian Institute of Chartered Accountants (CICA) on their exposure draft of generally accepted privacy principles designed to be used as an operational framework to manage privacy risks.

    4/20/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede SAS No. 74, Compliance Auditing Considerations in Audits of Governmental Entities and Recipients of Governmental Financial Assistance and would revise AU section 801.

    2/12/09 – Comments on an exposure draft of a proposed statement on auditing standards that would supersede Statement on Auditing Standards No. 70, Service Organizations, which contains guidance for auditors auditing the financial statements of entities that use a service organization and for auditors reporting on controls at a service organization.

1/9/09 - Comments to AICPA on Proposed Preface to Codification of Statements on Auditing Standards, Principles Governing an Audit Conducted in Accordance With Generally Accepted Auditing Standards and Proposed Statement on Auditing Standards, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance With Generally Accepted Auditing Standards.

    11/3/08 Comments on an exposure draft of a proposed statement on auditing standards that would amend AU Section 722, Interim Financial Information.

    8/12/08 – Comments on an exposure draft of a proposed statement on auditing standards that would amend AU Section 325, Communicating Internal Control Related Matters Identified in an Audit.

    7/2/08 – Comments on the proposed Statement on Auditing Standards (SAS) No. 114 (Redrafted), The Auditor’s Communication With Those Charged with Governance, that would supersede existing SAS No. 114. The proposed SAS represents the redrafting of SAS No. 114 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

  • Comments to the AICPA on Proposed Statement on Auditing Standards No. 103 (Redrafted), Audit Documentation

    7/2/08 – Comments on the proposed Statement on Auditing Standards (SAS) No. 103 (Redrafted), Audit Documentation, that would supersede existing SAS No. 103. The proposed SAS represents the redrafting of SAS No. 103 to apply the Auditing Standards Board’s clarity drafting conventions and to converge with International Standards on Auditing.

    4/22/07 – Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their Exposure Draft -- Proposed Interpretation 101-17 – Networks and Network Firms and Proposed New Definitions of Network and Network Firms and Proposed Revised Definition – Firm, Under Rule 101, dated August 13, 2007.

    12/21/07 – A response to the AICPA’s invitation to comment on planned improvement to the Uniform CPA Examination.

5/21/07 – Comments to the AICPA on their Exposure Draft of a Proposed Statement on Standards for Accounting and Review Services – Elimination of Certain References to Statements on Auditing Standards and Incorporation of Appropriate Guidance into Statements on Standards for Accounting and Review Services.

5/15/07 – Comments to AICPA and NASBA on proposed revisions to AICPA/NASBA Uniform Accountancy Act Sections 23, 7, and 14.

    11/14/06 – Comments to the AICPA Professional Ethics Executive Committee (PEEC) on their Exposure Draft - Omnibus Proposal of Professional Ethics Division Interpretations and Rulings dated September 8, 2006. Comments are on the Proposed Deletion of Rulings Under Rule 101, and Proposed Revision to Interpretation 101-3 under Rule 101: Performance of Nonattest Services: Forensic Accounting Services and Tax Compliance Services.

8/16/06 – Comments to the Tax Executive Committee of AICPA on their Proposed Statement on Standards for Tax Services No. 9, Quality Control, December 30, 2005.

    5/24/06 Comments to the AICPA Auditing Standards Board on the ASB’s Exposure Draft of a Proposed Statement on Standards for Attestation Engagements – Reporting on an Entity’s Internal Control Over Financial Reporting (January 19, 2006). ASB issued the exposure draft to enhance the practitioner’s ability to identify and evaluate control deficiencies and to report on internal control.

  • Comments to AICPA ASB on Exposure Draft: Proposed Statement on Auditing Standards: The Auditor’s Communication with those Charged with Governance

    5/24/06 – Comments to the AICPA Auditing Standards Board on the ASB’s Exposure Draft of a Proposed Statement on Auditing Standards: The Auditor’s Communication with those Charged with Governance. A proposed SAS that will replace SAS No. 61, Communication With Audit Committees, as amended.

    1/27/06 – Comments to AICPA Professional Ethics Executive Committee on Proposed Omnibus Proposal: Proposed Interpretation 101-17, Performance of Client Advocacy Services, Fact Witness Testimony, and Forensic Accounting Services, Under Rule 101, Independence, dated September 15, 2005

    11/2/05 – Comments to the AICPA Auditing Standards Board on the ASB’s Exposure Draft of a proposed Statement on Auditing Standards entitled “Communication of Internal Control Related Matters Noted in an Audit.” The proposed standard is intended to strengthen the communication of internal control related matters for non-issuer entities.

    8/16/05 – Comments on AICPA Professional Ethics Executive Committee’s Exposure Draft, Omnibus Proposal of Professional Ethics Division Interpretations and Rulings, June 17, 2005.

4/13/04 – Comments on AICPA’s proposed changes which primarily involve additional performance requirements for review engagements as they relate to fraud, analytical procedures and inquiries.

    8/1/03 - Society’s respone to the AICPA’s request for comments regarding the recently issued exposure draft on proposed revisions to the AICPA Standards for Performing and Reporting on Peer Reviews.

9/24/02 - Society comments on amendments to SSARS No. 1 and SSARS No. 4 as proposed in the AICPA Accounting and Review Services Committee (ARSC) exposure draft.

8/30/02 - General and specific comments on and suggestions for changes to the exposure draft.

    7/22/02 - Concurrence with the revisions of the interpretations and belief that they are necessary to strengthen definitions and to assure appropriate compliance because they address many of the current uncertainties about independence.

 

 
Comments to ASB - Back to Top

    5/11/05 – Comments to the AICPA Auditing Standards Board on proposed clarifications to terminology used in professional literature.

    6/26/02 - Society comments on the proposed amendment to SAS 50, which would prohibit an accountant from providing a written report on the application of accounting principles not involving facts and circumstances of a specific entitiy (hypothetical trasnsactions).

 
Comments to COSO - Back to Top

    10/31/07 – Comments to the The Committee of Sponsoring Organizations of the Treadway Commission on their September 2007 discussion document on guidance on monitoring internal control systems.

1/13/06 – Response to the Committee of Sponsoring Organizations’ (COSO) request for comment on their exposure draft of proposed Guidance for Smaller Public Companies Reporting on Internal Control over Financial Reporting.

 
Letters to the Department of Health and Human Services - Back to Top

    4/23/08 – A letter requesting clarification of OMB Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations,” Requirements for Reporting Certain Medicaid Payments of County and City SEFA

 
Comments to the Department of the Treasury - Back to Top

8/27/10 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposed revisions to the Bank Secrecy Act regulations applicable to Money Services Businesses with regard to stored value or prepaid access payment methods.

    12/16/09 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposed rulemaking to amend the relevant Bank Secrecy Act information sharing rules to allow certain foreign law enforcement agencies, and state and local law enforcement agencies, to submit requests for information to financial institutions.

8/19/09 – Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to include mutual funds within the general definition of ‘‘financial institution’’ in rules implementing the Bank Secrecy Act.

    3/3/09 – Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to reorganize Bank Secrecy Act regulations.

    11/29/07 – Comments to the U.S. Department of Treasury’s Advisory Committee on the Auditing Profession on their discussion outline, which includes a list of issues and potential consideration points regarding the auditing profession.

 
Comments to the FASB - Back to Top

9/22/14 - Comments on a proposed accounting standards update, the objective of which is to simplify the measurement of inventory by measuring at the lower of cost and net realizable value and to more closely align the measurement of inventory in GAAP with the measurement of inventory in International Financial Reporting Standards. 
9/22/14 - Comments on a proposed accounting standards update, the objective of which is to reduce complexity, cost and time in the assessment of extraordinary events and to alleviate uncertainty surrounding extraordinary items.
7/31/14 - Comments on a proposed accounting standards update, the objective of which is to provide guidance on when and how an acquired entity that is a business or nonprofit activity can apply pushdown accounting in its separate financial statements.
7/11/14 - Comments on a proposed statement of financial accounting concepts, the purpose of which is to provide the FASB with a framework for identifying information that could be appropriate for inclusion in notes to financial statements and relevant to the users of those statements.
2/26/14 - Comments on a proposed accounting standards update, the objective of which is to reduce the diversity in practice related to classification by creditors of government-guaranteed residential mortgage loans entitling a creditor to the full unpaid principal balance of the loan upon foreclosure.
12/19/13 - Comments on a proposed accounting standards update with proposed amendments that are intended to resolve the diverse accounting treatment of share-based payment awards that require a specific performance target to be achieved for employees to benefit.
12/19/13 - Comments on a proposed accounting standards update, the objective of which is to eliminate the use of different methods in practice and thereby reduce existing diversity surrounding the accounting for hybrid financial instruments issued in the form of a share under U.S. GAAP.
12/19/13 - Comments on a proposed accounting standards update, the objective of which is to improve financial reporting by reducing the cost and complexity associated with the incremental reporting requirements for a development stage entity.
10/9/13 - Comments on a proposed accounting standards update with proposed amendments that would permit a private company to elect not to apply variable interest entity (VIE) guidance for assessing whether it should consolidate a lessor entity under specified conditions.
9/16/13 - Comments on a proposed accounting standards update, the primary purposes of which are to amend the Master Glossary of the FASB Accounting Standards Codification® to include one definition of public business entity for use in U.S. GAAP and identify the types of business entities that would be excluded from the scope of the guide.
9/16/13 - Comments on a proposed accounting standards update the objective of which is to clarify when an in substance repossession or foreclosure occurs such that all or a portion of the loan should be derecognized and the real estate property recognized.
9/11/13 - Comments on a proposed accounting standards update that proposes changes to both lessee and lessor accounting and would supersede IAS 17, Leases (and related Interpretations), in International Financial Reporting Standards (IFRS) and the requirements in Topic 840, Leases (and related Subtopics) of the FASB accounting standards codification.
8/21/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance about an accounting alternative for the recognition, measurement, and disclosure of identifiable intangible assets acquired in a business combination.
8/21/13 - Comments on a proposed accounting standards update with proposed amendments that would provide guidance about an accounting alternative for the subsequent measurement of goodwill.
8/21/13 - Comments on a proposed accounting standards update with amendments that would provide two simpler approaches, the combined instruments approach and the simplified hedge accounting approach, to account for swaps that are entered into for the purposes of economically converting variable-rate borrowing to fixed-rate borrowing.
8/1/13 - Comments on a proposed accounting standards update that would address reporting issues under Subtopic 205-20 by changing the criteria for reporting discontinued operations and enhancing convergence of the FASB’s and the IASB’s reporting requirements for discontinued operations.
6/21/13 - This FASB Invitation to Comment was issued to solicit comments on a proposed guide for use by the FASB and the Private Company Council (PCC) in considering alternatives for private companies within U.S. generally accepted accounting principles (GAAP).
5/14/13 - Comments on a proposed accounting standards update, the objective of which is is to provide financial statement users with more decision-useful information about an entity’s involvement in financial instruments, while reducing the complexity in accounting for those instruments.
4/22/13 - Comments on a proposed accounting standards update, the objective of which is to address whether the Fed Funds Effective Swap Rate (OIS) should be included as a U.S. benchmark interest rate for hedge accounting purposes, in addition to UST and LIBOR.
4/22/13 - Comments on a proposed accounting standards update, the objective of which is to eliminate the diversity in practice in the presentation of unrecognized tax benefits.
3/19/13 - Comments on a proposed accounting standards update, the objective of which is to improve the existing accounting and disclosure guidance on repurchase agreements and other transactions involving a transfer and a forward agreement to repurchase the transferred assets at a fixed price from the transferee.
12/17/12 - Response to an invitation to comment on FASB Discussion Paper – Disclosure Framework. The objective and primary focus of the FASB project is to improve the effectiveness of disclosures in notes to financial statements by clearly communicating the information that is most important to users of each entity’s financial statements.
11/8/12 - Response to an invitation to comment (ITC) on FASB Discussion Paper–Private Company Decision-Making Framework, A Framework for Evaluating Financial Accounting and Reporting Guidance for Private Companies. The purpose of the ITC is to gather input from stakeholders about the appropriateness, completeness, and cost effectiveness of the draft private company (nonpublic business entity) decision-making framework. 

10/19/12 - Comments on a proposed accounting standards update, the objective of which is to improve the presentation of reclassifications out of accumulated other comprehensive income by disclosing their effect on the respective line items in net income if the item being reclassified is required under U.S. GAAP to be reclassified in its entirety to net income.

10/16/12 - Comments on a proposed accounting standards update, the objective of which is to provide users of financial statements with more decision-useful information about entity-level exposures to liquidity risk and interest rate risk.

9/14/12 - Comments on a proposed accounting standards update, the objective of which is to provide guidance for the recognition, measurement, and disclosure of obligations resulting from joint and several liability arrangements for which the total amount under the arrangement is fixed at the reporting date, except for obligations addressed within existing guidance in U.S. GAAP.

3/7/12 - Comments on a proposed accounting standards update (a joint project of FASB and IASB) to clarify the principles for recognizing revenue and to develop a common revenue standard for U.S. GAAP and IFRSs.

2/10/12 - Comments on a proposed accounting standards update to address the diversity in practice related to entities that invest in real estate. The amendments in this proposed Update would provide accounting guidance for an entity that meets the criteria to be an investment property entity. The proposed amendments also would introduce additional presentation and disclosure requirements for an investment property entity.

2/10/12 - Comments on a proposed accounting standards update of Topic 810, Consolidation. The proposed amendments in this Update would affect all reporting entities that are required to evaluate whether they should consolidate another entity. The proposed amendments are expected to most significantly affect the financial reporting of entities that are involved with variable interest entities.

2/10/12 - Comments on a proposed accounting standards update of Topic 946, Financial Services—Investment Companies. The amendments in this proposed Update would affect the scope, measurement, presentation, and disclosure requirements for investment companies in U.S. generally accepted accounting principles (GAAP).

9/27/11 - Comments on a proposed accounting standards update, the objective of which is to resolve the diversity in practice about whether the guidance in Subtopic 360-20 applies to a parent that ceases to have a controlling financial interest in a subsidiary that is in substance real estate as a result of default on the subsidiary’s nonrecourse debt.

6/6/11 - Comments on a proposed accounting standards update, the objective of which is to simplify how an entity is required to test goodwill for impairment by permitting a qualitative assessment.

4/27/11 - Comments on a proposed accounting standards update addressing the differences in the offsetting (netting) requirements in U.S. GAAP and IFRSs.

4/27/11 - Response to an invitation to comment, issued by the FASB and IASB, on their discussion paper considering how best to improve and simplify standards for financial reporting of financial instruments, and, at the same time, provide users with clearer and more complete information.

4/1/11 - Comments to the FASB on this Supplementary Document, issued by the FASB as a step preceding the development of an Exposure Draft of a proposed Accounting Standards Update. This supplementary document presents an impairment model that the FASB and IASB believe will enable them to satisfy at least part of their individual objectives for impairment accounting while achieving a common solution to impairment.

1/12/11 - Comments to the FASB on a Proposed Accounting Standards Update – Transfers and Servicing (Topic 860) Reconsideration of Effective Control for Repurchase Agreements. The objective of the proposed update is to improve the accounting for repurchase agreements (repos) and other agreements that both entitle and obligate a transferor to repurchase or redeem financial assets before their maturity.

12/15/10 – Comments to the FASB on a Proposed Accounting Standards Update – Leases (Topic 840), a joint project of the FASB and IASB to develop a new approach to lease accounting that would ensure that assets and liabilities arising under leases are recognized in the statement of financial position. 

10/22/10 - Comments to the FASB on a Proposed Accounting Standards Update – Revenue Recognition (Topic 605) Revenue from Contracts with Customers. The proposed guidance, part of joint FASB and IASB effort to clarify revenue recognition principles, specifies the principles that an entity would apply to report information about revenue and cash flows arising from its contracts to provide goods or services to customers.

9/30/10 - Comments to the FASB on a Proposed Accounting Standards Update – Financial Instruments (Topic 825) and Derivatives and Hedging (Topic 815): Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities. The objective of the proposed Update is to provide financial statement users with a more timely and representative depiction of an entity’s involvement in financial instruments, while reducing the complexity in the accounting.

9/30/10 - Comments to the FASB on a Proposed Accounting Standards Update – Comprehensive Income (Topic 220): Statement of Comprehensive Income. The amendments in this proposed Update would require that all components of comprehensive income be reported in a continuous financial statement that displays the components of net income and the components of other comprehensive income within comprehensive income.

9/7/10 - Comments to the FASB on a Proposed Accounting Standards Update – Fair Value Measurements and Disclosures (Topic 820): Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs. This proposed Update is a result of the continuing efforts of the FASB and the IASB to develop common requirements for measuring fair value and for disclosing information about fair value measurements.
 

9/7/10 - Comments to the FASB on a Proposed Accounting Standards Update – Plan Accounting—Defined Contribution Pension Plans (Topic 962): Reporting Loans to Participants by Defined Contribution Pension Plans. The objective of the proposed Update is to clarify how loans to participants should be classified and measured by defined contribution pension benefit plans.  

8/20/10 - Comments to the FASB on a Proposed Accounting Standards Update: Receivables (Topic 310) – Disclosure of Certain Loss Contingencies. To improve adequacy and timeliness of information in assessing the likelihood, timing, and magnitude of future cash outflows associated with loss contingencies

    7/2/09 – Comments on FASB's proposed FSP 157-g that would amend FASB Statement No. 157, Fair Value Measurements, to provide application guidance for estimating the fair value of investments in investment companies that have calculated net asset value per share in accordance with the AICPA Audit and Accounting Guide, Investment Companies.

    6/18/09 – Comments on a discussion paper of a joint FASB and IASB project, the objective of which is to clarify the principles for recognizing revenue and create a joint revenue recognition standard for US GAAP and IFRSs that companies can apply across various industries and transactions.

    11/14/08 – Comments on FASB’s proposed Statement of Financial Accounting Standards – Accounting for Transfers of Financial Assets, an amendment of FASB Statement No. 140, which is a revision of the August 2005 FASB Exposure Draft, Accounting for Transfers of Financial Assets.

    7/7/08 – Comments on a potential revision to the October 2006 Proposed Statement, Not-for-Profit Organizations: Mergers and Acquisitions that would enhance financial reporting of mergers and acquisitions of not-for-profit organizations.

4/7/08 – Comments on proposed FASB Staff Position (FSP) FAS 117-a – Endowments of Not-for-Profit Organizations: Net Asset Classification of Funds Subject to an Enacted Version of the Uniform Prudent Management of Institutional Funds Act, and enhanced disclosures (issued 02/22/08).

    12/28/07– Comments on proposed FASB Staff Position (FSP) FAS 157-a – Application of FASB Statement No. 157 to FASB Statement No. 13 and its related interpretive accounting pronouncements that address leasing transactions (issued 11/28/07).

    5/24/07 – Proposed SFAS 133 Implementation Issue – Scope Exceptions: Whether Options (Included Embedded Conversion Options) Are Indexed to both an Entity’s Own Stock and Currency Exchange Rates.

    11/13/06 – Respone to FASB’s invitation to comment on Preliminary Views - Conceptual Framework for Financial Reporting: Objectives of Financial Reporting and Qualitative Characteristics of Decision-Useful Financial Reporting Information.

6/23/05 – Comments on FASB’s proposed Statement of Financial Accounting Standard that seeks to clarify an enterprise’s responsibility to select accounting principles in conformity with the GAAP hierarchy.

  • Comments on Proposed FASB Staff Position FIN 46(R) – b

    2/3/05 – Comments on proposed FASB Staff Position (FSP) No. FIN 46(R) – b, "Implicit Variable Interests Resulting from Related Party Relationships under FASB Interpretation No. 46 (revised December 2003), Consolidation of Variable Interest Entities."

    10/22/03 - Comments regarding FASB’s exposure draft of a Proposed Statement of Financial Accounting Standards: Employers’ Disclosure about Pensions and Other Postretirement Benefits, an amendment of FASB Statements No. 87, 88, and 106 and a replacement of FASB Statement No. 132.

    6/25/04 – comments on a proposed statement that addresses the accounting for share-based payment transactions in which an enterprise receives employee services in exchange for equity instruments or liabilities associated with the enterprise.

11/26/03 - General and specific comments on FASB Exposure Draft: Proposed Interpretation, Consolidation of Variable Interest Entities, a modification of FASB Interpretation No. 46, and recommendation for a comprehensive standard on off-balance sheet entities.

8/30/02 - Comments on the proposed interpretation, which seeks to provide guidance on the accounting for special-purpose entities.

    7/9/02 - Society comments on a FASB exposure draft dealing with the accounting for derivatives and hedging.

 
Comments to FAF - Back to Top

12/12/11 - The NYSSCPA President’s letter to the FAF acknowledging the need to improve the financial reporting of private companies calling for an autonomous standard-setting body to implement differential standards for private companies that is not subject to FASB ratification.

7/28/11 - Comments on recommendations made by the Blue-Ribbon Panel on Private Company Financial Reporting to the Financial Accounting Foundation regarding differential standards and a separate standard-setting entity for private companies.

 
Comments to the Financial Crimes Enforcement Network - Back to Top

12/6/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to amend the definition of “monetary instrument'' in the Bank Secrecy Act (``BSA'') regulations for purposes of the international transport of currency and monetary instrument reporting requirement to include tangible prepaid access devices.

11/14/11 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposal to require electronic filing of Bank Secrecy Act Reports.

8/27/10 - Comments to the Financial Crimes Enforcement Network Agency (FinCEN) of the Treasury Department on FinCEN’s proposed revisions to the Bank Secrecy Act regulations applicable to Money Services Businesses with regard to stored value or prepaid access payment methods.

 
Comments to GAO - Back to Top

    8/14/06 Comments to GAO on Government Auditing Standards 2006 Revision Exposure Draft (GAO-06-729G), proposed revisions to “Yellow Book” auditing standards.

 
Comments to the GASB - Back to Top

10/30/08 – Comments to the Governmental Accounting Standards Board on their exposure draft of a proposed statement, the objective of which is to incorporate the hierarchy of generally accepted accounting principles into the Governmental Accounting Standards Board’s authoritative literature.

    6/30/08 – Comments to the Governmental Accounting Standards Board on their exposure draft of fund balance reporting and governmental fund type definitions.

5/2/03 - Society comments on the GASB exposure draft on disclosure of the other than pensions post employment benefits (OPEB) actuarial liability information.

 
Comments to Government Officials - Back to Top

7/9/14 - The Society believes believe preserving the cash basis method for pass-through entities, personal service corporations and farmers is critically important. Requiring a change to the accrual method would have a significant impact on job growth and the economy in New York State.
1/2/14 - Comments on bipartisan legislation that would limit the Public Company Accounting Oversight Board (PCAOB) from requiring mandatory audit firm rotation for public companies and bring the lingering firm rotation debate in the U.S. to a swift conclusion.
12/18/13 - Comments on limitation on the use of the cash method of accounting for businesses as proposed by Chairman Baucus in his Cost Recovery and Accounting Discussion Draft (November 21, 2013).

7/10/12 - NYSSCPA President Gail M. Kinsella sent a letter to United States Senator Charles Schumer (D-NY) on July 10 urging him to co-sponsor Senate Bill 845. The bill would allow partnerships, corporations, trusts, estates, and individuals to better submit timely, accurate returns and reduce the need for extended and amended returns.

3/14/13 - A formal letter in opposition to legislative leaders regarding amendments added to the 2013 New York State budget bills that removed the requirements for annual internal audits.
11/7/12 - Letter requesting an extension of the CPE reporting year by four weeks in light of the devastation wrought by Hurricane Sandy, and noting that the state took similar action after Hurricane Irene. 

9/26/12 - NYSSCPA President Gail M. Kinsella sent a letter to the New York State members of the U.S. Senate Finance Committee      (Senator Charles Schumer D-NY) and the U. S. House Ways and Means Committee (Congressmen Joseph Crowley D-NY,  Charles B. Rangel D-NY, Tom Reed R-NY) proposing targeted, short-term exceptions to the 10% additional tax levied on early withdrawals from individual retirement plans to alleviate economic hardships faced by taxpayers as a result of the economic crisis. (The letter linked here is to Senator Schumer).

8/16/12 – NYSSCPA President Gail M. Kinsella sent a letter to United States Senator Kirsten Gillibrand (D-NY) on August 16 urging her to co-sponsor Senate Bill 1232. The bill would modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) to exclude appraisers of Employee Stock Ownership Plans (ESOPs). 

11/15/11 - Letter to US Congressman Jerome Nadler requesting co-sponsorship and support of H.R. 1864, the Mobile Workforce State Income Tax Simplification Act of 2011.

6/30/11 - Letter to NYS Governor Andrew M. Cuomo recommending the signing into law of bill A.4881-B/S.2628-A to grant cross-border practice mobility in accordance with Section 23 of the Model Uniform Accountancy Act.

2/16/11 - Letter to New York City Department of Finance Commissioner Frankel requesting resumption of the Tax Representatives and Practitioners Program (TaxRAPP), noting its benefit to both practitioners and the department.

2/7/11 - Letter to NYS Governor Andrew M. Cuomo recommending the continuation of the Office of the New York State Taxpayer Rights Advocate, that its role be codified, and suggestions as to its term, reporting, and other aspects.

9/28/10 - Letter to the NYS Congressional Delegation requesting action to repeal section 9006, which imposes unreasonably burdensome Form 1099 reporting requirements on all business taxpayers, particularly on small businesses.

    10/29/09 – Response to a request from the NYC Department of Finance Commissioner for written comments on tax administration simplification suggestions discussed at a meeting with the NYSSCPA New York State, Multistate and Local Taxation Committee in September 2009.

7/14/06 – A letter from the Society to Senators Clinton and Schumer offering suggestions concerning pending legislation affecting the estate tax and the need for certainty in estate tax planning

11/7/05 – The Society’s position paper prepared by the Committee for Practical Reform of the Tax System, detailing a proposal for a Simplified Exact Transparent Tax (SET) tax system as a tax reform solution, was sent to the New York Congressional Delegation after the President’s Advisory Panel on Federal Tax Reform released their report.

    5/19/04 Letter to Governor George Pataki concerning a proposal to restrict administrative hearing rights for New York State taxpayers, as proposed in Part L of Budget Bill S. 6060-A/ A. 9560-A.

    4/23/03 - Comments on Attorney General Eliot Spitzer's proposed legislation for governing not-for-profit organizations in New York State.

 
Comments House Ways and Means and Senate Finance - Back to Top

7/17/08 Comments to the U.S. House Ways and Means and Senate Finance Committees and Senators Schumer and Clinton concerning expired provisions related to charitable giving by S Corporation shareholders.

    10/31/06 – Comments to the House Ways and Means Committee on the Tax Technical Corrections Act of 2006 HR6264 which contains a provision which would in effect repeal application of the lower 15% tax rate on distributions from certain small business exporters.

 
Comments to HUD - Back to Top

 
Comments to the IASB - Back to Top

  • Comments to the IASB on an Exposure Draft – Financial Instruments: Amortised Cost and Impairment

    6/28/10 - Comments on an IASB exposure draft representing the second phase of a project to replace IAS 39 Financial Instruments: Recognition and Measurement, the stated objective of which is to improve the decision-usefulness of financial statements for users by improving amortised cost measurement, in particular the transparency of provisions for losses on loans and for the credit quality of financial assets.


8/28/08 – Comments to the IASB in response to their invitation to comment on a discussion paper concerning financial instruments with the characteristics of equity.

    9/28/07 – Comments to the International Accounting Standards Board on their exposure draft of an international financial reporting standard (IFRS) for small and medium-sized entities.

 
Comments to the IAASB - Back to Top

9/29/14 - Comments on the IAASB proposed revisions to ISAs that are intended to address the practical challenges arising from the evolving aspects of disclosures.
7/18/14 - Comments on this IAASB proposed revision to ISA 720 that is intended to bring enhanced clarity and consistency regarding the auditor’s responsibilities related to other information given the notable increase in the weight that users place on information in annual reports beyond the audited financial statements.
11/19/13 - Comments on an exposure draft on expansion of the auditor's report and that includes proposed new ISA 701, Communicating Key Audit Matters in the Independent Auditor’s Report, and a number of proposed revised ISAs, including revisions to ISA 700, Forming an Opinion and Reporting on Financial Statements.
3/18/13 - NYSSCPA response to a request for comments by the International Auditing and Assurance Standards Board (IAASB) on proposed ISA 720 (Revised), The Auditor’s Responsibilities Relating to Other Information in Documents Containing or Accompanying Audited Financial Statements and the Auditor’s Report Thereon. The proposals extend the scope of the extant standard and the auditor’s responsibilities and include suggested auditor reporting responsibilities.

10/2/12 - NYSSCPA response to the International Auditing and Assurance Standards Board (IAASB) Invitation to Comment: Improving the Auditor’s Report (ITC). The ITC sets out the IAASB’s indicative direction proposed for the future of the auditor’s report.

9/14/11 - NYSSCPA response to a request by the International Auditing and Assurance Standards Board (IAASB) for comments on a consultation paper that seeks to determine whether there are common views among users of audited financial statements and other stakeholders about the usefulness of auditor reporting.

5/31/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on a discussion paper that explores issues and perspectives regarding financial statement disclosures and auditing disclosures in a financial statement audit.

2/11/11 - Comments on proposals relating to International Auditing Practice Statements (IAPSs) including withdrawal of existing IAPSs, clarification of the status and authority of new IAPSs, proposed amendments to the Preface to the International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements, and Proposed International Auditing Practice Statement IAPSs 1000, Special Considerations in Auditing Complex Financial Instruments.

4/4/11 - NYSSCPA response to the request by the International Auditing and Assurance Standards Board (IAASB) for comments on the proposed IAASB Strategy and Work Program for 2012 – 2014.

10/1/03 - Comments on a proposed IAS regarding the review of interim financial information performed by an auditor, and recommendation for full integration with IAS 910.

 
Comments on IFAC - Back to Top

2/3/05 – Comments on ISA 230 (Revised), “Audit Documentation;” amendment to ISA 330, “The Auditor’s Procedures in Response to Assessed Risks;” amendment to ISQC 1, “Quality Control for Firms that Perform Audits and Reviews of Historical Financial Information and Other Assurance and Related Services Engagements.”

4/13/04 – Comments on the International Federation of Accountants proposal governing group audits.

    1/17/03 - Specific comments on this proposed International Auditing Practice Statement (IAPS) of the International Federation of Accountants (IFAC) for Reporting on Compliance with International Financial Reporting Standards.

 
Comments on IESBA - Back to Top

8/14/14 - Comments to the International Ethics Standards Board for Accountants (IESBA) on proposed changes to certain provisions addressing non-assurance services for audit clients.

 
Comments to International Valulation Standards Council - Back to Top

3/28/14 - Comments to the International Valuation Standards Council (IVSC) on their exposure draft of the first chapter of a rolling project to provide Illustrative Examples for many of the valuation concepts and principles discussed in the International Valuations Standards (IVS) Framework.

 
Comments to the IRS - Back to Top

8/14/14 - Comments to the International Ethics Standards Board for Accountants (IESBA) on proposed changes to certain provisions addressing non-assurance services for audit clients.
2/27/13 - Comments on proposed regulations (REG-130507-11) providing guidance for the net investment tax imposed under section 1411. Section 1411 was added by the Health Care and Education Reconciliation Act of 2010, effective for tax years beginning after December 31, 2012, and imposes a 3.8% tax on “net investment income” of higher income individuals and certain estates and trusts to fund the Act.

9/4/12 - Comments regarding temporary and proposed regulations that provide guidance on the estate and gift tax applicable exclusion amount, in general, as well as on the applicable requirements for electing portability of a deceased spousal unused exclusion (DSUE) amount to the surviving spouse and on the applicable rules for the surviving spouse’s use of this DSUE amount.

5/3/12 - The NYSSCPA International Taxation Committee offered comments to the Internal Revenue Service as it identified the reporting of foreign retirement plans, in particular, Canadian registered retirement savings plans and Canadian registered retirement funds (together referred to as “RRSPs”), held by U.S. persons, as a significant issue that deserves additional attention from Treasury and the IRS in order to lend clarity to their tax treatment.

4/19/12 - Response to a request for comments regarding when (and under what circumstances) transfers by a trustee of all or a portion of the principal of an irrevocable trust (Distributing Trust) to another irrevocable trust (Receiving Trust), that result in a change in the beneficial interests in the trust, are not subject to income, gift, estate, or generation-skipping transfer taxes.

3/19/12 - Comments regarding IRB 2012-8, February 21, 2012, REG-130302-10, Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations Reporting of Specified Foreign Financial Assets (T.D. 9567). Temporary regulations relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest.

10/21/11 - Response to IRS Notice 2011-82 inviting public comments on specific issues which have been identified for consideration in proposed regulations to be issued under section 2010(c).

5/31/11 - Comments to the IRS indicating circumstances in which additional guidance might be beneficial with respect regulations on basis reporting by securities brokers and basis determination for stock (Final Regulations 1.1012-1(c)(10), 1.1012-1(e)(12), 1.6045A-1(d), 1.6045B-1(g)).

5/23/11 - Recommendations to the IRS to improve tax reporting, specifically, recommendations on changes to certain tax filing due dates.

5/23/11 - Comments to the IRS regarding the effect on an S corporation shareholder’s stock basis of prior year losses that were not deductible because of the basis limitation on deductibility of losses.

7/1/11 - Comments to the IRS in response to IRS Notice 2011-48 inviting public comments on the content and administration of the registered tax return preparer competency examination.

9/28/10 - Comments to the IRS regarding new requirements with respect to the reporting of payments made in the course of a payor’s trade or business. The new requirements are in IRC Section 6041, which was amended by section 9006 of the Patient Protection and Affordable Care Act of 2010. Very generally, the amendments expand existing information reporting requirements (generally on form 1099) to apply to payments made to corporations and to include certain payments of gross proceeds and with respect to property.

7/11/08 – A response to an IRS request for comment on proposed regulations under § 2642(g)(1) for relief from late generation skipping transfer (GST) elections.

    5/16/08 – A response to IRS request for comment on Notice 2008-32 providing interim guidance on the treatment under § 67 of the Internal Revenue Code of investment advisory costs and other costs subject to the 2-percent floor under § 67(a) that are bundled.

9/14/07 – Comments to the IRS on their discussion draft of a redesigned Form 990, Return of Organization Exempt from Income Tax, filed by many public charities and other exempt organizations.

4/6/07 – Comments in response to IRS Notice 2007-21 requesting comment in connection with a study being conducted by Treasury and IRS on the organization and operation of donor advised funds and supporting organizations.

12/7/05 – Comments to the Internal Revenue Service pursuant to IRS proposed regulations 111257-05: Proposed rulemaking standards for recognition of tax-exempt status if private benefit exists or if an applicable tax-exempt organization has engaged in excess benefit transaction(s).

    9/15/03 - Society’s response to Treasury’s request for comments on proposed regulations relating to the assumption of and definition of liabilities under section 752 of the Internal Revenue Code.

5/27/03 - NYSSCPA strongly urges Congress to address simplification issues either in IRS regulations or in future legislation.

A specially appointed NYSSCPA task force identifies the more egregious areas of the Internal Revenue Code that are eligible for simplification, outlines why they are complex and offers solutions to assure proper compliance.

1/29/03 - Specific comments pursuant to Internal Revenue Service Announcement 2002-87 on proposed revisions to IRS Form 990, Return for Organization Exempt from Income Tax.

 
Comments to ISACA - Back to Top

12/3/12 - Comments to ISACA (Information Systems Audit and Control Association) on an exposure draft of proposed standards for an information technology assurance framework.

    7/5/06 – Comments to the Information Systems Audit and Control Association (ISACA) on their proposed Information System Auditing Procedure that discusses the effect of the Sarbanes-Oxley Act of 2002 on financial statement auditors considering the integration of Information Technology in their procedures.

    3/31/04 Society’s comments to the Information Systems Audit and Control Associations on Proposed Information System Auditing Guidelines on Business Continuity Planning, Computer Forensics and Mobile Computing and on Proposed Information System Auditing Procedure on Penetration Testing and Vulnerability Analysis.

 
Comments on NASBA - Back to Top

1/30/08 – A response to the National Association of State Boards of Accountancy invitation to comment on their exposure draft of the UAA Model Education Rules 5-1 & 5-2.

    7/7/05 – Comments to the National Association of State Boards of Accountancy on proposed revisions to the Uniform Accountancy Rules 5-1 and 5-2 dealing with education requirements.

 
Comments to the New York City Department of Housing Preservation and Development - Back to Top

8/4/14 - Comments and suggestions to NYC HPD regarding appropriate form and language for the CPA's certification on Form J-10b.2 Affidavit by Certified Public Accountants and Statement by Certified Public Accountants Required by Section 421(a).
3/11/14 - NYSSCPA comments on proposed amendments to the "J-51 Rules" regarding professional certification of the cost of major capital improvements and related identified expenses by certified public accountants.

 
Comments to the New York State Board for Public Accountancy - Back to Top

9/13/10 – Comments to the New York State Board for Public Accountancy of the New York State Education Department on proposed new Section 70.10 of the Regulations of the Commissioner of Education to establish a mandatory quality review program for the profession of public accountancy.

 
New York State Executive Budget - Back to Top

 
Comments to the NY State Department of Taxation and Finance - Back to Top

6/25/09 – A response to an invitation to comment from the NY State Department of Taxation and Finance regarding the implementation and administration of the Metropolitan Commuter Transportation Mobility Tax (MCTMT).

11/26/08 – A response to the NY State Department of Taxation and Finance to a request for comment on a proposal to remove provisions of the regulations providing for a “temporary stay” exception for purposes of determining resident status for New York State personal income tax purposes.

7/17/08 – A response to the NY State Department of Taxation and Finance to a request for comment while they are in the process of developing amendments to the provisions of the personal income tax regulations that define the term “Resident Individual”for income tax purposes.

 
Comments to the NYS IAC - Back to Top

 
Letters to NYSDTF - Back to Top

11/1/13 - Proposal of amendments to the Procedural Regulations and Personal Income Tax Regulations to implement certain of the recommendations of the Task Force on Regulation of Tax Return Preparers. 20 NYCRR section 158.12 and Part 2600.

 
Comments to the PCAOB - Back to Top

2/4/14 - The Public Company Accounting Oversight Board ("PCAOB") is reproposing amendments to its standards to improve transparency of public company audits requiring disclosure in the auditor's report of the name of the engagement partner and the names, locations, and extent of participation of other public accounting firms in the audit and the locations and extent of participation of other persons not employed by the auditor.
12/10/13 - Comments to the Public Company Accounting Oversight Board on Release No. 2013-005, Proposed Auditing Standards – The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion; The Auditor's Responsibilities Regarding Other Information in Certain Documents Containing Audited Financial Statements and the Related Auditor's Report; and Related Amendments to PCAOB Standards.
7/2/13 - Comments to the Public Company Accounting Oversight Board on Release 2012-004, a reproposal of a new auditing standard, Related Parties; amendments to certain PCAOB auditing standards regarding significant unusual transactions; and other amendments to PCAOB auditing standards. The reproposed standard would supersede the Board's existing auditing standard on related parties, AU sec. 334, Related Parties.
6/18/13 - The NYSSCPA sent a letter to certain members of New York's congressional delegation urging support for the bill which would, among other things, prevent the PCAOB from requiring mandatory audit firm rotation.
5/28/13 - The Public Company Accounting Oversight Board ("PCAOB" or "Board") is proposing a framework for reorganizing the existing interim and PCAOB issued auditing standards into a topical structure with a single integrated numbering system. In addition, the PCAOB is proposing certain conforming amendments to Rule 3101, Certain Terms Used in Auditing and Related Professional Practice Standards, and Rule 3200T, Interim Auditing Standards. The Board also is proposing certain related amendments to the PCAOB auditing standards and proposing to rescind certain interim auditing standards that the Board believes are no longer necessary under the proposed reorganization.

5/17/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2012-001, a proposed standard that would supersede the PCAOB’s interim standard AU sec. 334, Related Parties. The proposed standard and amendments address evaluation of a company's identification of related party transactions, identifying and evaluating a company's accounting and disclosure of significant unusual transactions and obtaining an understanding of a company's financial relationships and transactions with executive officers sufficient to identify risks of material misstatement.

2/28/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-008 proposing transitional amendments to AU sec. 380, Communication With Audit Committees, and reproposing an auditing standard, Communications with Audit Committees, that would supersede the Board's interim standards AU sec. 380 and AU sec. 310, Appointment of the Independent Auditor, and related amendments to PCAOB standards.

1/4/12 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-007, proposed amendments to PCAOB standards that would: (1) require registered public accounting firms to disclose the name of the engagement partner, (2) amend the Annual Report Form to require firms to disclose the name of the engagement partner for each audit report already required to be reported on the form, and (3) require disclosure in the audit report of other independent public accounting firms and other persons that took part in the audit.

12/13/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-006, a concept release to solicit public comment on ways that auditor independence, objectivity and professional skepticism could be enhanced, including the possible approach of mandatory audit firm rotation.

9/27/11 - Comments to the Public Company Accounting Oversight Board on Release No. 2011-003, a concept release to solicit public comment on the potential direction of a proposed standard-setting project on the content and form of reports on audited financial statements, specifically potential changes to the auditor's reporting model based on concerns of investors and other financial statement users.

9/13/10 – Comments to the Public Company Accounting Oversight Board on Release No. 2010-003 (Docket No. 028), a proposed auditing standard which would supersede the Board's standard, AU section 330, The Confirmation Process, and related amendments to the Board's auditing standards.

9/10/09 - Comments to the Public Company Accounting Oversight Board on Release No. 2009-005, a concept release to solicit public comment on whether the PCAOB should require the auditor with final responsibility for the audit to sign the audit report in their own name rather than firm name.

2/18/09 – Comments to the Public Company Accounting Oversight Board on Release No. 2008-006 - Proposed Auditing Standards Related to the Auditor’s Assessment of and Response to Risk, with comment on efforts to improve the risk assessment procedures undertaken during an audit.

    2/11/09 – Comments to the Public Company Accounting Oversight Board on Release No. 2008-006, specifically addressing Appendix 4, The Auditor's Responses to the Risks of Material Misstatement, page A4–13–37.

    12/17/07 – Comments to the Public Company Accounting Oversight Board on their Preliminary Staff Views (October 17, 2007) – An Audit of Internal Control that is Integrated with an Audit of Financial Statements: Guidance for Auditors of Smaller Public Companies.

    9/7/07 – Comments to the Public Company Accounting Oversight Board on Release No. 2007-008 – Proposed ethics and independence rule, Rule 3526, Communication with Audit Committees Concerning Independence, that would supersede the Board's interim independence requirement.

  • Comments to the PCAOB on Release No. 2007-007 – Proposed Amendments to Board Rule 4003(b)

    7/24/07 – Comments to the PCAOB on Release No. 2007-007; Docket Matter No. 24 – Proposed Amendments to Limit Board Rule 4003’s Fixed Periodic Inspection Requirement to Firms That Regularly Issue Audit Reports.

2/23/07 – Comments to the Public Company Accounting Oversight Board on Release No. 2006-007 – Proposed Auditing Standard: An Audit of Internal Control over Financial Reporting that is Integrated with an Audit of Financial Statements, and Related Other Proposals.

2/22/05 – Comments on PCAOB Release No. 2004-015 – Proposed Ethics and Independence Rules concerning Independence, Tax Services, and Contingent Fees.

    1/20/04 Society’s comments to the PCAOB regarding its proposed rules on audit documentation and amendment to interim auditing standards, and suggestion to incorporate a glossary of terms.

    11/21/03 - Comments on the Public Company Accounting Oversight Board’s exposure draft of proposed rules that would integrate the audits of internal control over financial reporting with the audits of financial statements.

 
Proposed Accounting Standards Updates - Back to Top

5/31/13 - The main objective in developing this proposal was to provide financial statement users with more decision-useful information about the expected credit losses on financial assets and other commitments to extend credit held by a reporting entity at each reporting date. These proposed amendments also would reduce complexity by replacing the numerous existing impairment models in current U.S. GAAP with a consistent measurement approach.
5/29/13 - Stakeholders have raised concerns that certain disclosure requirements in paragraph 820-10-50-2 of the FASB Accounting Standards Codification®, which was effective for nonpublic entities for annual periods beginning after December 15, 2011, would potentially provide proprietary information about nonpublic entities through the dissemination of their employee benefit plans’ financial statements on the regulator’s Web site. The amendments in this proposed Update would address those concerns by permitting an indefinite deferral of certain quantitative disclosure requirements in paragraph 820-10-50-2(bbb) for investments held by a nonpublic employee benefit plan in its plan sponsor’s own nonpublic entity equity securities.

 
Comments on Regulation Crowdfunding - Back to Top

1/21/14 - Comments to the SEC which is proposing new regulations on Crowdfunding under the Securities Act of 1933 and the Securities Exchange Act of 1934 to implement the requirements of Title III of the Jumpstart Our Business Startups Act that would prescribe rules governing the offer and sale of securities under new Section 4(a)(6) of the Securities Act of 1933.

 
Comments to the SEC - Back to Top

7/28/11 - Comments to the Securities and Exchange Commission on an SEC Staff Paper: Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers – Exploring a Possible Method of Incorporation (May 26, 2011).

9/9/10 - Comments to the SEC on interactive data to improve financial reporting with observations obtained from the implementation of the Extensible Business Reporting Language (XBRL).

    7/27/09 - Comments to the Securities and Exchange Commission on proposed amendments to the custody rule under the Investment Advisers Act of 1940. The amendments, among other things, would require registered investment advisers that have custody of client funds or securities to undergo an annual surprise examination by an independent public accountant to verify client funds and securities.

    3/5/09 – Comments to the Securities and Exchange Commission on their proposed Roadmap for the potential use of financial statements prepared in accordance with International Financial Reporting Standards (“IFRS”) as issued by the International Accounting Standards Board by U.S. issuers for purposes of their filings with the Commission. This Roadmap sets forth several milestones that, if achieved, could lead to the required use of IFRS by U.S. issuers in 2014.

    7/23/08 – Comments to the Securities and Exchange Commission on proposed rules requiring companies to provide financial statement information in an interactive data format using XBRL.

    3/7/08 – Comments to the Securities and Exchange Commission on a proposal to amend temporary rules that would require companies that are non-accelerated filers to include in their annual reports an attestation report of their independent auditor on internal control over financial reporting for fiscal years ending on or after December 15, 2008.

    11/12/07 – Comments to the Securities and Exchange Commission on a concept release to obtain information about the public’s interest in allowing U.S. issuers to prepare financial statements in accordance with International Financial Reporting Standards for purposes of complying with the rules and regulations of the Commission.

    9/21/07 – Comments to the Securities and Exchange Commission on Release No. 33-8818 – Acceptance from Foreign Private Issuers of Financial Statements Prepared in Accordance with International Financial Reporting Standards without Reconciliation to U.S. GAAP.

2/27/07 – Comments to the Securities and Exchange Commission on Release Nos. 33-8762; 34-54976; File No. S7-24-06 – Proposed Interpretive Guidance for management regarding its evaluation of internal control over financial reporting. The interpretive guidance sets forth an approach by which management can conduct a top-down, risk-based evaluation of internal control over financial reporting.

2/12/07 – Comments to the Securities and Exchange Commission on Release No. 34-55005 [International Series Release No. 1300; File No. S7-12-05] Termination of a Foreign Private Issuer's Registration of a Class of Securities Under Section 12(G) and Duty to File Reports Under Section 13(A) or 15(D) of the Securities Exchange Act of 1934.

9/20/06 – Comments to the Securities and Exchange Commission regarding issues raised in Concept Release No. 34-54122 Concerning Management’s Reports on Internal Control Over Financial Reporting, involving Section 404(a) and PCAOB Auditing Standard No. 2.

8/24/04 – comments to the SEC Division of Market Regulation on the potential negative effects of SFAS 150 on broker-dealers’ business succession plans, and related guidance on New York Stock Exchange Information Memo 04-23.

8/19/02 - Comments in support of and suggestions to the SEC’s proposed rules which seek to bring about fuller and more timely information flow into the capital markets.

 
Comments on the Second Exposure Draft - Back to Top

10/18/12 - The Business Valuation Committee of the New York State Society of Certified Public Accountants (NYSSBV) has reviewed the Second Exposure Draft of Proposed Changes for the 2014-15 Edition of the Uniform Standards of Professional Appraisal Practice (the “Exposure Draft”) and has summarized its comments.

 
Comments to the Tax Commission of the City of New York - Back to Top

12/18/12 - NYSSCPA proposed independent auditor’s report for purposes of NYC Form TC309, Accountant's Certification, to conform with the Clarity Auditing Standards issued by the AICPA effective for audits of entities with a fiscal year ending on or after December 15, 2012.

 
Society Letters - Back to Top

7/9/14 - The Society believes believe preserving the cash basis method for pass-through entities, personal service corporations and farmers is critically important. Requiring a change to the accrual method would have a significant impact on job growth and the economy in New York State.

    3/4/05 – Response to request from the NY State CFR Interagency Committee for advice on options for the reporting of sales of management services on the consolidated fiscal report.