Society Comment Letters

• Letter to the Department of Health and Human Services Requesting Clarification on Circular A-133 and the Reporting of Certain Medicaid Payments
  

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 AICPA PEEC on 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

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.

• Comments to FASB on Proposed FSP FAS 117-a – Endowments of Not-for-Profit Organizations: Net Asset Classification of Funds Subject to an Enacted Version of the UPMIFA, and Enhanced Disclosures (issued 02/22/08)

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).

• Comments to HUD Regarding a Proposal for a Roster of Approved Independent Public Accountants

4/7/08 – A response to the Department of Housing and Urban Development’s request for comment on a proposed rule that would establish a roster of approved independent public accountants and public accounting firms that would be permitted to perform audits or related services required by participants in certain HUD programs and submitted to HUD.

• Comments to the SEC on Release Nos. 33-8889; 34-57258 – Internal Control Over Financial Reporting in Exchange Act Periodic Reports of Non-Accelerated Filers

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.

• Comments to NASBA on their Exposure Draft of the UAA Model Education Rules 5-1 & 5-2

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.

• Comments to FASB on Proposed FSP FAS 142-f – Determination of the Useful Life of Intangible Assets

1/16/08 – Comments on proposed FASB Staff Position (FSP) FAS 142-f– Determination of the Useful Life of Intangible Assets (Issued 11/26/07) that would amend Statement No. 142, Goodwill and Other Intangible Assets, paragraph 11d, to allow an entity to consider its own assumptions about renewal or extension in determining the useful life of a recognized intangible asset.

• Comments to FASB on Proposed FSP FAS 157-b – Effective Date of FASB Statement No. 157

1/16/08 – Comments on proposed FASB Staff Position (FSP) FAS 157-b – Effective Date of FASB Statement No. 157 (issued 12/14/07) that would amend FASB Statement No. 157, Fair Value Measurements, to delay the effective date.

• Comments on Proposed FSP FAS 157-a – Application of FASB Statement No. 157 to FASB Statement No. 13

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

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

• Comments to the PCAOB on Preliminary Staff Views – An Audit of Internal Control that is Integrated with an Audit of Financial Statements

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.

• Comments to Treasury on Discussion Outline for Consideration by the Advisory Committee on the Auditing Profession

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 SEC on Concept Release No. 33-8831 – Concept Release on Allowing U.S. Issuers to Prepare Financial Statements in Accordance with International Financial Reporting Standards

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.

• Comment to IRS - Recommendation to Improve Tax Reporting Related to Forms 1040 Filed on Extension and Schedules K-1 from Partnership Returns

11/1/07 – A comment paper sent to IRS offering a recommendation to improve tax reporting related to Forms 1040 filed on extension and Schedules K-1 from Partnership Returns on extension to the same due date.

• Comments to COSO on Guidance on Monitoring Internal Control Systems

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.

• Statement Submitted for the Record on Single Audit Hearing of the Subcommittee on Federal Financial Management, Government Information, Federal Services, and International Security

10/25/07 – Statement of the NYSSCPA Submitted for the Record of October 25, 2007 Hearing Entitled “Single Audits: Are They Helping to Safeguard Federal Funds”, By the Subcommittee on Federal Financial Management, Government Information, Federal Services, and International Security of the United States Senate Committee on Homeland Security and Governmental Operations.

• Comments to the IASB on Exposure Draft: International Financial Reporting Standard for Small and Medium-Sized Entities

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 SEC on Release No. 33-8836 – Discussion Paper for Consideration by the SEC Advisory Committee on Improvements to Financial Reporting
  

  9/28/07 – Comments to the Securities and Exchange Commission on a discussion paper for consideration by the SEC Advisory Committee on improvements to financial reporting. The discussion paper is to provide a discussion of issues, views and potential consideration points that the Committee may evaluate.

• Comments to the SEC on Release No. 33-8818 – Foreign Private Issuers of Financial Statements Prepared in Accordance With IFRS Without Reconciliation to U.S. GAAP
  

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.

• Comments to the SEC on Release No. 33-8819 – Smaller Reporting Company Regulatory Relief and Simplification

  9/17/07 – Comments to the Securities and Exchange Commission on Release Nos. 33-8819; 34-56013; 39-2447; File No. S7-15-07 on proposed rule amendments relating to disclosure and reporting requirements for smaller companies under the Securities Act of 1933 and the Securities and Exchange Act of 1934.

• Comments to the IRS on Draft Redesigned Form 990, Return of Organization Exempt from Income Tax

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.

• Comments to the PCAOB on Release No. 2007-008 – Proposed Ethics and Independence Rule 3526, Communication with Audit Committees Concerning Independence
  

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 SEC on Release No. 34-56010 – Exemption of Compensatory Employee Stock Options from Registration under Section 12(g) of the Securities Exchange Act of 1934

9/4/07 – Comments to the Securities and Exchange Commission on Release No.34-56010 concurring with proposal to provide two exemptions from the registration requirements of the Securities Exchange Act of 1934 for compensatory employee stock options.

• 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.

• Comments to the SEC on Release Nos. 33-8811; 34-55930; File No. S7-24-06 – Definition of a Significant Deficiency

7/18/07 – Comments to the Securities and Exchange Commission on Release Nos. 33-8811; 34-55930; File No. S7-24-06 – definition of the term “significant deficiency” in the Commission’s rules.

• Comments to the SEC on Release No. 34-55912 – Proposed Rule on Auditing Standard No. 5

7/12/07 – Comments to the Securities and Exchange Commission on Release No. 34-55912; File No. PCAOB-2007-02 – Proposed Rule on Auditing Standard No. 5, An Audit of Internal Control Over Financial Reporting That is Integrated with an Audit of Financial Statements, and Related Independence Rule and Conforming Amendments

• Comments to AICPA Peer Review Board on Exposure Draft – Proposed Revisions to the AICPA Standards for Performing and Reporting on Peer Reviews, April 16, 2007

6/27/07 – 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, which in part are intended to create a single set of program standards.

• Comments to AICPA on Auditing Standards Board’s March 20, 2007 Discussion Paper, Improving the Clarity of ASB Standards
  

6/11/07 – Comments to the Auditing Standards Board (ASB) of AICPA on the ASB’s March 20, 2007 discussion paper on improving the clarity of the ASB standards.

• Comments to FASB on Proposed Statement 133 Implementation Issue No. C21, Whether Options (Including Embedded Conversion Options) Are Indexed to both an Entity’s Own Stock and Currency Exchange Rates
  

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.

• Comments to AICPA on Exposure Draft of a Proposed Statement on Standards for Accounting and Review Services: Elimination of Certain References to Statements on Auditing Standards and …
  

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.

• Comments to PCAOB on Release No. 2007-002: Concept Release Concerning Scope Rule 3523, Tax Services for Persons in Financial Reporting Oversight Roles
  

5/16/07 – Comments to the Public Company Accounting Oversight Board on Release No. 2007-002 – a concept release concerning Scope Rule 3523, Tax Services for Persons in Financial Reporting Oversight Roles.

• Comments to PCAOB on Release No. 2007-003: Proposed Auditing Standard – Evaluating Consistency of Financial Statements and Proposed Amendments to Interim Auditing Standards
  

5/16/07 – Comments to the Public Company Accounting Oversight Board on Release No. 2007-003 – a Proposed Auditing Standard – Evaluating Consistency of Financial Statements and Proposed Amendments to Interim Auditing Standards.

• Comments to AICPA and NASBA on Exposure Draft-Proposed Revisions to AICPA/NASBA Uniform Accountancy Act Sections 23, 7, and 14
  

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

• Comments to FASB -- Invitation to Comment – Valuation Guidance for Financial Reporting
  

4/16/07– Comments to FASB in response to their invitation to comment on the need, if any, for valuation guidance in financial reporting, including implementation guidance, specificity of valuation guidance, and whether FASB or another organization should be involved in providing guidance.

• Comments to Treasury and IRS on IRS Notice 2007-21: Study on Donor Advised Funds and Supporting 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.

• Comments on FASB Exposure Draft – Disclosures about Derivative Instruments and Hedging Activities - an amendment of FASB Statement No. 133
  

3/02/07– Comments and responses to FASB on their exposure draft regarding disclosures about derivative instruments and hedging activities, which would amend FASB Statement No. 133, Accounting for Derivative Instruments and Hedging Activities.

• Comments to the SEC on Release Nos. 33-8762; 34-54976 – Proposed Interpretive Guidance for Management’s Report on Internal Control Over Financial Reporting

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.

• Comments to PCAOB 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

2/23/07 – 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.

• Comments to the SEC on Release No. 34-55005 - 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)

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.

• Comments on FASB Exposure Draft -- Proposed Statement of Financial Accounting Standards - Not-for-Profit Organizations: Mergers and Acquisitions

1/29/07– Comments to FASB on their exposure draft of a proposed financial accounting standard dealing with mergers and acquisitions in not-for-profit accounting.

• Comments on FASB Exposure Draft -- Proposed Statement of Financial Accounting Standards - Not-for-Profit Organizations: Goodwill and Other Intangible Assets Acquired in a Merger or Acquisition

1/29/07– Comments to FASB on their exposure draft of a proposed financial accounting standard dealing with goodwill and other intangible assets acquired in a merger or acquisition in the not-for-profit area.

• Comments to AICPA PEEC on Exposure Draft - Omnibus Proposal of Professional Ethics Division Interpretations and Rulings dated September 8, 2006: Proposed Interpretation 101-16: Indemnification/Limitation of Liability Provisions and ADR Clauses in Engagement Letters under Rule 101.

11/20/06 – 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 Interpretation 101-16: Indemnification/Limitation of Liability Provisions and ADR Clauses in Engagement Letters under Rule 101, Independence.

• Comments to AICPA PEEC on Exposure Draft - Omnibus Proposal of Professional Ethics Division Interpretations and Rulings dated September 8, 2006: Proposed Deletion of Rulings Under Rule 101, and Proposed Revision to Interpretation 101-3 under Rule 101: Performance of Nonattest Services

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

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.

• Comments to the House Ways and Means Committee on Tax Technical Corrections Act of 2006 HR6264 – Section 7, Amendment Related to the Jobs and Growth Tax Relief Reconciliation Act of 2003 (Repeal of 15% IC-DISC)

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 the SEC on Proposed Amendment [Release No. 33-8735; File No. S7-03-06] Concerning Executive Compensation Disclosure
  

10/20/06 – Comments to the Securities and Exchange Commission regarding Release No. 33-8735 which is a proposed amendment to the disclosure requirements for executive and director compensation.

• Comments to AICPA on Exposure Draft of Proposed Statement on Auditing Standards, Entitled “Omnibus – 2006”

9/21/06 – Comment to the AICPA in support of their Exposure Draft of Proposed Statement on Auditing Standards, Entitled “Omnibus – 2006”

• Comments to AICPA on Exposure Draft of Proposed Statement on Standards for Attestation Engagements, Entitled “SSAE Hierarchy”

  9/20/06 – Comments to the AICPA on their Exposure Draft of Proposed Statement on Standards for Attestation Engagements, entitled “SSAE Hierarchy”, an initiative to both identify the applicable attestation publications that should be followed when conducting attestation engagements and to clarify the authority of such publications.

• Comments to the SEC on Concept Release No. 34-54122 Concerning Management’s Reports on Internal Control Over Financial Reporting

  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.

• Comments to AICPA on Proposed SSTS No. 9, Quality Control for Tax 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.

• Comments to GAO on Proposed 2006 Revision to Government Auditing Standards (Yellow Book)
  

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 NYS Board for Public Accountancy on the Computer Based CPA Exam
  

8/4/06 – A report to the NYS Board for Public Accountancy on implementation concerns and recommendations for improvement on the computer based CPA exam in New York State.

• Comments to GASB on Preliminary Views – Accounting and Financial Reporting for Derivatives

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.

• Comments to PCAOB on Release No. 2006-004 – Proposed Rules on Periodic Reporting by Registered Public Accounting Firms

7/21/06 – Comments to the Public Company Accounting Oversight Board on Release No. 2006-004 – Proposed Rules on Periodic Reporting by Registered Public Accounting Firms.

• Comments to PCAOB on Release No. 2006-005 – Proposed Rules on Succeeding to the Registration Status of a Predecessor Firm

  7/21/06 – Comments to the Public Company Accounting Oversight Board on Release No. 2006-005 – Proposed Rules on Succeeding to the Registration Status of a Predecessor Firm.

• Letter to Senators Clinton and Schumer on Pending Legislation Affecting the Estate Tax

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.

• Comments to ISACA on Proposed IT Control Objectives for Sarbanes Oxley – 2nd Edition

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.

• Comments to AICPA ASB on Exposure Draft: Proposed Statement on Standards for Attestation Engagements, Reporting on an Entity’s Internal Control Over Financial Reporting
  

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.

• Comments to IRS in Response to Notice of Proposed Rulemaking 137243-02 Regarding an Updating of Section 7216 Regulations

3/6/06 – Comments to the Internal Revenue Service pursuant to Notice of Proposed Rulemaking 137243-02: Guidance Necessary To Facilitate Electronic Tax Administration—Updating Of Section 7216 Regulations (Treas. Reg. § 301.7216-2)

• Comments to ISACA on Proposed Information System Auditing Procedure on Business Application Change Control

2/9/06 – Comments to the Information Systems Audit and Control Association (ISACA) on their proposed Standards Documents Under Exposure: Business Application Change Control

• Comments to AICPA on Proposed Omnibus Proposal: Proposed Interpretation 101-16 and the Proposed Deletion of Ethics Rulings Nos. 94 and 95

1/27/06 – Comments to AICPA Professional Ethics Executive Committee on Proposed Omnibus Proposal: Proposed Interpretation 101-16, Indemnification, Limitation of Liability, and ADR Clauses in Engagement Letters, Under Rule 101, Independence; and Proposed Deletion of Ethics Rulings No. 94 and No. 95 Under Rule 101, Independence, dated September 15, 2005

• Comments to AICPA on Proposed Omnibus Proposal: Proposed Interpretation 101-17, Performance of Client Advocacy Services, Fact Witness Testimony, and Forensic Accounting Services, Under Rule 101, Independence
  

  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

• Comments to AICPA on Proposed Revision to "Other Considerations" in Interpretation 101-1, Interpretation of Rule 101, Under Rule 101, and Proposed Conceptual Framework for AICPA Independence Standards
  

1/18/06 – Comments to AICPA Professional Ethics Executive Committee on Proposed Revision to "Other Considerations" in Interpretation 101-1, Interpretation of Rule 101, Under Rule 101, and Proposed Conceptual Framework for AICPA Independence Standards, dated September 15, 2005.

• Comments on Proposed FASB Staff Position FSP FAS 133a – Accounting for Unrealized Gains (Losses) Relating to Derivative Instruments Measured at Fair Value under Statement 133

1/13/06 – Comments to FASB on a proposed FASB Staff Position (FSP) FAS 133-a, Accounting for Unrealized Gains and Losses Relating to Derivative Instruments Measured at Fair Value under Statement 133.

• Comments to FASB on Selected Issues Relating to Assets and Liabilities with Uncertainties

1/13/06 – Response to FASB invitation to comment on a selected issues relating to assets and liabilities with uncertainties. An effort to attempt to clarify and to eliminate inconsistencies in existing guidance regarding the role of probability and uncertainty when defining and measuring assets and liabilities.

• Comments to COSO on Proposed Guidance for Smaller Public Companies Reporting on Internal Control over Financial Reporting

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.

• Comments to IRS on Proposed Regulations 111257-05 Regarding Recognition of Tax Exempt Status

  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).

• Comments on FASB Exposure Draft of a Proposed SFAS: Earnings Per Share, an Amendment of FASB Statement No. 128
  

  12/1/05 – Comments to FASB on a new version of this exposure draft of a proposed SFAS on earnings per share that would amend FAS 128.

• Comments on FASB Exposure Draft of a Proposed SFAS: Consolidated Financial Statements, Including Accounting and Reporting of Noncontrolling Interests in Subsidiaries, a Replacement of ARB No. 51
  

  12/1/05 – Comments to FASB on their proposed statement of financial accounting standard on consolidated financial statements, including accounting and reporting of noncontrolling interests in subsidiaries. This would be a replacement of ARB No. 51.

• Comments on ISACA Proposed Information Systems Auditing Standard on Audit Evidence
  

11/7/05 – Comments to the Information Systems Audit and Control Association on their proposed information system auditing standard on audit evidence.

• Transmittal of Society's Position Paper on Tax Reform to NY Congressional Delegation After Release of Report by the President’s Advisory Panel on Federal Tax Reform
  

  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.

• Comments to IRS on Credit Default Swaps (Response to IRS Notice 2004-52)
  

11/7/05 – Comments to the Internal Revenue Service in response to a request in IRS Notice 2004-52 seeking comment on the tax treatment of credit default swaps.

• Comments to AICPA ASB on Exposure Draft: Communication of Internal Control Related Matters Noted in an Audit.

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.

• Comments on FASB Exposure Draft: Proposed SFAS - Accounting for Transfers of Financial Assets, an amendment of FASB Statement No. 140

10/19/05 – Comments to FASB on and a proposed amendment to FAS 140 to revise and clarify the issues relating to the standards governing the accounting for transfers of financial assets.

• Comments on FASB Exposure Draft: Proposed SFAS - Accounting for Servicing of Financial Assets, an amendment of FASB Statement No. 140

10/19/05 – Comments to FASB on and a proposed amendment to FAS 140 to revise and clarify the issues relating to the standards governing the accounting for servicing of financial assets.

• Comments on FASB Exposure Draft: Proposed SFAS - Accounting for Certain Hybrid Financial Instruments

10/19/05 – Comments to FASB on and a proposed amendment to FAS 140 to revise and clarify the issues relating to the standards governing the accounting for certain hybrid financial instruments.

• Comments on Proposed FASB Staff Position FSP FAS 13-b – Accounting for Rental Costs Incurred during a Construction Period

  8/31/05 – Comments to FASB on a proposed FASB Staff Position (FSP) FAS 13-b, Accounting for Rental Costs Incurred during a Construction Period.

• Comments to AICPA ASB on Exposure Draft of “Eight Proposed Statements on Auditing Standards Related to Risk Assessment (June 2005)”

8/31/05 – Comments to the AICPA Auditing Standards Board on the ASB’s Exposure Draft of “Eight Proposed Statements on Auditing Standards Related to Risk Assessment (June 2005)”. Comments on each of the eight proposed standards.

• Comments to AICPA on Omnibus Proposal of Professional Ethics Division Interpretations and Rulings, June 17, 2005

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.

• Comments to NASBA on Proposed Revisions to the Uniform Accountancy Rules 5-1 and 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 on FASB Exposure Draft of a Proposed Statement of Financial Accounting Standards: The Hierarchy of Generally Accepted Accounting Principles

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 to AICPA on Proposal of Professional Ethics Division Interpretations and Rulings, April 18, 2005

  6/23/05 – Comments to AICPA on proposal of Professional Ethics Division interpretations and rulings, April 18, 2005, most of which address guidance to members in determining the effect on member independence of direct or indirect financial interests.

• Comments to AICPA on Exposure Draft of Proposed Statement on Standards for Accounting and Review Services – Restricting the Use of an Accountant’s Compilation or Review Report

6/20/05 – Comments to the AICPA on a proposed statement on standards for accounting and review services on restricted uses of an accountant’s compilation and review reports.

• Comments to AICPA on Exposure Draft of Proposed Statement on Standards for Accounting and Review Services – Omnibus Statement on Standards for Accounting and Review Services - 2005
  

  6/20/05 – Comments to the AICPA on a proposed statement on standards for accounting and review services on proposed amendments to SSARS 1 and SSARS 2.

• Comments to AICPA on Exposure Draft of Proposed Statement on Standards for Accounting and Review Services – Compilation of Specified Elements, Accounts, or Items of a Financial Statement and Proforma Financial Information

6/20/05 – Comments to the AICPA on a proposed statement on standards for accounting and review services regarding proposed changes to compilation of specified elements, accounts, or items of a financial statement and proforma financial information, most of which would conform SSARS to existing audit literature.

• Comments to ASB on Proposed Statement on Standards for Attestation Engagements, “Defining Professional Standards for Attestation Engagements”

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

• Comments on PCAOB Release No. 2005-002 - Proposed Auditing Standard – Reporting on the Elimination of a Material Weakness, March 31, 2005

5/11/05 – Comments to PCAOB on Release No. 2005-002 – Proposed Auditing Standard – Reporting on the Elimination of a Material Weakness, March 31, 2005. A proposal to create a mechanism for engagements to report on the elimination of internal control weaknesses.

• Comments to ASB on Proposed Statement on Auditing Standards: Audit Documentation

  5/11/05 – Comments to the AICPA Auditing Standards Board on a proposed Statement on Auditing Standards on audit documentation.

• Society's Position Paper on Tax Reform (Adobe Acrobat required)

4/21/05 – 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.

• Society's Letter on Proposal Linking Licensure to Tax Compliance (Adobe Acrobat required)

3/10/05 -- Letter from the Society president to Gov. George Pataki and the legislative leaders concerning Part L of Budget Bill S00995B and A01925B.

• Comments to NY State CFR Interagency Committee Regarding Sales of Management Services

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.

• 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."

• Comments on IFAC Exposure Draft ISA 230 (Revised), Audit Documentation and amendments to ISA 330

  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.”

• Comments on ISACA Proposed Information Systems Auditing Standard on Irregularities and Illegal Acts

  12/30/04 – Comments to the Information Systems Audit and Control Association on their proposed information system auditing standard on irregularities and illegal acts.

• Letter Regarding NYC Form RPIE-2003

  09/14/04 – Letter to the NY City Department of Finance with questions regarding the new Form RPIE-2003 (Real Property Income and Expense statements).

• Comments to PCAOB Regarding Audits of Financial Statements of Non-Issuers

  9/7/04 – Letter to PCAOB regarding PCAOB’s Staff Questions and Answers – Audits of Financial Statements of Non-Issuers Performed Pursuant to the Standards of the Public Company Accounting Oversight Board, June 30, 2004.

• Comments on FASB Exposure Draft: Proposed Statement of Financial Accounting Standards, Fair Value Measurements

  9/7/04 – Comments to FASB on various aspects of the proposed standard for fair value measurements.

• Comments to the SEC on the Effects of SFAS 150 on Business Succession Plans of Broker-Dealers and Guidance on NYSE Memo 04-23

  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.

• Comments on FASB Exposure Draft: An Interpretation of FASB Statement 143, Accounting for Conditional Asset Retirement Obligations

7/30/04 – comments on a proposed interpretation requiring recognition of an asset retirement liability in all circumstances unless sufficient information is not available to estimate fair value.

• Letter to Congress on Stock Options

  6/25/04 – Letter to the New York Congressional Delegation regarding stock options and the Society’s general support for the FASB’s proposed standard on stock option accounting.

• Comments on FASB Exposure Draft: Exposure Draft: Proposed Statement of Financial Accounting Standards, Share-Based Payment, an amendment of FASB Statements No. 123 and 95

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.

• Comments and Suggestions Regarding the New York State Unemployment Insurance Regulations

5/28/04 - Comments submitted to the NY State Departments of Taxation and of Labor suggesting improvements, clarifications and additions to the NY State unemployment insurance regulations.

• Comments for Consideration by the National Taxpayer Advocate in Preparation of Its Annual Report to Congress

5/28/04 - Response to request from National Taxpayer Advocate Nina Olson for comments and suggestions for improvements to the tax system to be incorporated in the National Taxpayer Advocate’s annual report to Congress.

• Letter to the Governor of New York State on Legislative Proposal Concerning Administrative Hearing Rights

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.

• Comments on FASB Exposure Draft: Proposed Statement of Financial Accounting Standards, Inventory Costs, an amendment of ARB No. 43, Chapter 4

4/13/04 - Comments indicating that the exposure draft does not result in substantive improvements in accounting for inventory and recommendations for a revised or new proposal.

• Comments on FASB Exposure Draft: Proposed Statement of Financial Accounting Standards, Earnings Per Share, an amendment of FASB Statement No. 128

  4/13/04 – Comments on FASB exposure draft that presents three changes to the methodology for computing earnings per share.

• Comments on FASB Exposure Draft: Proposed Statement of Financial Accounting Standards, Exchange of Productive Assets, an amendment of APB Opinion No. 29

4/13/04 – Comments of FASB exposure draft dealing with exchanges of similar productive assets.

• Comments of FASB Exposure Draft: Proposed Statement of Financial Accounting Standards, Accounting Changes and Error Corrections – a replacement of APB Opinion No. 20 and FASB Statement No. 3

4/13/04 – Comments in support of and suggestions to the exposure draft which seeks to converge U.S. GAAP and the IASB’s accounting standards regarding accounting changes and error corrections.

• Comments on IFAC Proposed Pronouncement: ISA 600 (Revised), “The Work of Related Auditors and Other Auditors in the Audit of Group Financial Statements” and IAPS, “The Audit of Group Financial Statements.”

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

• Comments on AICPA Exposure Draft: Proposed Statement on Standards for Accounting and Review Services – Performance of Review Engagements

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.

• Comments to ISACA on Proposed Information System Auditing Guidelines and Information System Auditing Procedure
  

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 PCAOB Release No. 2003-023 Proposed Auditing Standard on Audit Documentation and Proposed Amendment to Interim Auditing Standards

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

12/29/03 - Suggestions made to the New York City Tax Commission related to Form TC 201, Income and Expense Schedule for Rent Producing Properties.

• Comments on PCAOB Release No. 2003-021 Proposed Auditing Standard – References in the Auditors’ Reports to the Standards of the Public Company Accounting Oversight Board

12/2/03 - Society’s comments to the PCAOB regarding its proposed auditing standard on references in the auditors’ reports to the standards of the PCAOB.

• Comment on PCAOB Release No. 2003-022 Proposed Technical Amendments to Interim Standards Rules

  12/2/03 - Concurrence with PCAOB’s proposal to handle interim standards.

• Comments on Proposed Interpretation, Consolidation of Variable Interest Entities, a modification of FASB Interpretation No. 46

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.

• Comments on PCAOB Proposed Auditing Standard – An Audit of Internal Control over Financial Reporting Performed in Conjunction with an Audit of Financial Statements.

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.

• Comments on FASB Exposure Draft of Proposed Statement Regarding Employers’ Disclosure about Pensions and Other Postretirement Benefits

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.

• Comments on Proposed IAASB Exposure Draft: Review of Interim Financial Information Performed by the Auditor of an Entity

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 AcSEC Proposed Statement of Position: Allowance for Credit Losses

9/17/03 - Society’s comments addressing seven specific issues on AcSEC’s exposure draft of Statement of Position: Allowance for Credit Losses.

• Comments on IRS and Treasury Proposed and Temporary Regulations under IRC Section 752

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.

• Comments on Proposed FASB Staff Position – Applicability of FASB Statement No. 143 to Asbestos Removal

8/7/03 - Comments on a proposed FASB Staff Position regarding the applicability of FAS 143, Accounting for Asset Retirement Obligations, to legislative requirements on property owners to remove and dispose of asbestos or asbestos-containing materials.

• Comments to the AICPA Peer Review Board On Exposure Draft: Proposed Revisions to the AICPA Standards for Performing and Reporting on Peer Reviews

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 FASB Exposure Draft: Proposed Amendment to FASB Statement 140, Qualifying Special-Purpose Entities and Isolation of Transferred Assets

  7/30/03 - Society’s reply to FASB request for comment on the exposure draft of the proposed amendment to FASB Statement 140, Qualifying Special-Purpose Entities and Isolation of Transferred Assets.

• Comments on Proposal to Extend Tax Filing Deadline to April 30 for Individuals Who File Electronically

7/17/03 - Comments to congress to consider the unintended effects of a provision to extend the filing deadline for electronic returns to April 30th that would be counterproductive to efforts to advance electronic filing.

• Comments Pursuant to Internal Revenue Service Announcement 2003-29

7/17/03 - Comments regarding clarifications to existing requirements that section 501(c)(3) organizations must meet with respect to international grant-making and other international activities.

• Comments on Internal Revenue Service K-1 Matching Program: NYSSCPA Proposal for Form K-1

  6/26/03 - Society's comments on the IRS K-1 Matching Program and the redesign of form K-1, including submission of a draft of a proposed long form K-1.

• 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.

• Comments to the Auditing Standards Board On Exposure Draft of Seven Statements on Auditing Standards Related to Audit Risk

5/2/03 - Society comments to the Auditing Standards Board on the seven proposed statements on auditing standards related to audit risk.

• Comments to the GASB On Exposure Draft, Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions

  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 the State of New York Office of Attorney General's on Legislative Bill #06251-01-3

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

• Comments on Proposed Revisions to IRS Form 990, "Return for Organization Exempt from Income Tax."

  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 on IFAC Exposure Draft: Reporting on Compliance with International Financial Reporting Standards

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 FASB Proposal for Principles-Based Approach to U.S. Standard Setting

1/7/03 - Specific comments keyed to questions posed in FASB's proposal for a principles-based approach to U.S. accounting standard setting.

• Comments to the NY State Board for Public Accountancy regarding the acceptance of commissions by CPAs and Implementation of Sarbanes - Oxley

  1/7/03 - Letter to the NY State Board for Public Accountancy with comments regarding the acceptance of commissions and contingent fees and comments on a draft proposal regarding implementation of the Sarbanes - Oxley Act in New York State.

• Comment on November 19, 2002 Decision of the Appellate Division, First Department, in Banker's Trust Corporation v. New York City Department of Finance

12/20/02 - Comment on the November 19, 2002 decision reached by the Appellate Division and its potential effect on the construction of the statute of limitations in similar cases.

• Comments on FASB Exposure Draft: Accounting for Stock-Based Compensation -- Transition and Disclosure, a Proposed Amendment of FASB Statement No. 123

10/28/02 - Comments on and suggested amendments to proposed alternative transition methods to encourage companies to adopt the fair value method of accounting for stock-based employee compensation set forth in SFAS 123.

• Comments on AICPA ARSC Exposure Draft on the Proposed Statement on Standards of Accounting and Review Services: Omnibus -- 2002.

  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.

• Comments on IASB Exposure Draft on Proposed Improvements to International Accounting Standards

  9/16/02 - Society comments on proposed improvements set forth in the Exposure Draft, with indication that they are generally appropriate and should be adopted except as specifically identified in the comment letter.

• Comments on Proposed Statement on Auditing Standards: Auditing Fair Value Measurements and Disclosures

9/4/02 - Comments on a proposed auditing standard on the audit process for fair values.

• Comments on Exposure Draft AICPA/CICA Trust Services Principles and Criteria (Incorporating SysTrust and WebTrust), July 1, 2002, Version 1.0.

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

• Comments on FASB Exposure Draft, Proposed Interpretation, Consolidation of Certain Speical-Purpose Entities

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

• Comments on NYS Board of Regents Proposed Rule: Work Paper Documentation and Retention

  8/29/02 - Comments on an amendment to the Rules of the Regents of the State University of New York, Work Paper Documentation and Retention Proposal.

• Comments of Proposed SEC Rule: Additional Form 8-K Disclosure Requirements and Acceleration of Filing Date

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 AICPA PEEC Exposure Draft: Omnibus Proposal of professional Ethics Division Interpretations and Rulings

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 on FASB Exposure Draft of a Proposed Interpretation, Guarantor’s Accounting and Disclosure Requirements for Guarantees, Including Indirect Guarantees of Indebtedness of Others

  7/10/02 - Society comments in opposition to this exposure draft as substantially proposed.