February 2000

Board Approves Procedure to Authorize Society Comments

On February 4 the NYSSCPA board of directors approved a procedure for Society committees to follow when submitting official NYSSCPA comments to the Internal Revenue Service, Securities and Exchange Commission, Financial Accounting Standards Board, AICPA, and other groups. Previously, the Society's accounting and auditing and tax divisions implemented their own approval procedures, and certain other committees independently submitted Society comments. The Committee on Committee Operations (COCO) drafted the uniform procedure, taking the previous divisional procedures into account.

"We wanted Society comments to receive the same high level of scrutiny regardless of the originating committee," COCO Chair Carol Lapidus said. "This procedure will facilitate timely completion of comments and help to assure the Society's continued high quality of output."

The procedure outlines the following steps: First, the chair of a committee that wants to offer comments communicates with the chair of his or her oversight committee for concurrence on the need for comments. Next, while the committee prepares the comments, the oversight committee chair appoints one or more oversight committee members to act as an ad hoc task force to review the completed comments. Once the ad hoc task force approves the final comments, the Society's president will sign them with, if they choose, the chairs of the appropriate committee and oversight committee.

The new procedure also addresses completion of comments by multiple committees and special task forces organized by the president specifically to respond to a particular issue. In addition, the policy provides for resolution of differing opinions between the ad hoc task force and the committee that prepares the comments.

The Society has distributed the new procedure to all committee chairs and will include it in future editions of the Committee Operations Manual. The policy also is available at http://www.nysscpa.org. For more information, contact NYSSCPA Counsel James A. Woehlke at (212) 719-8347, (800) 633-6320, or jwoehlke@nysscpa.org. *