BDO United States

BDO United States

Assurance Publications

Comment Letters

BDO Seidman's comment letters on FASB and SEC proposals.

1/28/2010 Subsequent Events (Topic 855) - Amendments to Certain Recognition and Disclosure Requirements
BDO support's the Board's efforts to address the conflicts between ASC Topic 855 and the SEC's requirements. We generally agree with the approach the Board has proposed, but we suggest that the Board make two clarifying changes. We support the proposal to make the amendments effective upon issuance, and we urge the Board to act as soon as possible.
10/27/2009 Research and Development Assets Acquired and Contingent Consideration Issued in an Asset Acquisition
BDO does not support the ED because it does not align the accounting for intangible assets acquired in an asset acquisition with business combination accounting, but rather, it creates new inconsistencies in U.S. GAAP without a compelling benefit and also does not align the accounting for acquired intangible assets with internally-generated R&D costs that must be expensed.
10/27/2009 Accounting for Stock Dividends, Including Distributions to Shareholders with Components of Stock and Cash
BDO shares the view held by the majority of the Emerging Issues Task Force members that the stock portion of the dividend addressed in the proposed Accounting Standard Update should be treated as a share issuance that is reflected in earnings per share on a prospective basis rather than as stock dividend.
10/13/2009 BDO agrees most of the FASB's proposals to enhance fair value disclosures represent improvements, but believe the method of disclosing sensitivities for Level 3 fair value estimates will not be cost-beneficial.
71KB PDF File
8/27/2009 BDO agrees enhanced credit quality disclosures will improve transparency, but supports deferring the proposed standard for a year and shortening its requirements.
68KB PDF File
1/6/2009 BDO generally agrees with the changes reflected in the proposed Statement on Subsequent Events and supports the FASB’s proposal to move the guidance on this subject from the auditing literature to the accounting literature.
19KB PDF File
1/6/2009 BDO supports the FASB’s proposal to move the guidance on going concern from the auditing literature to the accounting literature but urges the FASB to rethink the expanded time horizon proposed in its proposed Statement on Going Concern.
29KB PDF File
8/11/2008 BDO Seidman urges the FASB to rethink its proposed disclosures about potential litigation and certain other loss contingencies.
77KB PDF File
8/1/2008 BDO Seidman responds to the SEC's request for comments on interactive data to improve financial reporting.
25KB PDF Document
7/23/2008 BDO Seidman asks the SEC to provide guidance about estimates of fair value in distressed markets. We also urge the SEC to recommend that the FASB and IASB be circumspect in extending fair value measurements to nonfinancial liabilities.
32KB PDF File
7/14/2008 BDO Seidman responds to the FASB’s request for additional comments on mergers and acquisitions of not-for-profit organizations.
36KB PDF File
6/5/2008 BDO Seidman comments on the FASB’s preliminary views regarding financial instruments with characteristics of equity.
39KB PDF File
5/29/2008 BDO Seidman generally supports the goal of enhanced reporting by foreign private issuers but suggests a few modifications to the SEC’s rule proposal.
34KB PDF File
5/2/2008 BDO Seidman evaluates the disclosure requirements in proposed FSP FAS 132(R)-a and suggests an alternative approach that is more flexible and easier to implement.
30KB PDF file
4/18/2008 BDO Seidman urges the FASB to trim the disclosures in proposed FSP FAS 117-a on endowments for not-for-profit organizations and suggests extending the effective date to allow an extra six months for implementation.
33KB PDF file
3/31/2008 BDO Seidman generally supports the recommendations of the SEC's CIFR advisory committee, but asks the committee to reconsider its recommendations in several areas, including industry-specific and activity-based accounting guidance.
53KB PDF file
1/21/2008 BDO Seidman urges the FASB to clarify the eligibility criteria for the proposed deferral of the effective date of Interpretation No. 48, Accounting for Uncertainty in Income Taxes, for nonpublic companies.
25KB PDF file
1/16/2008 BDO Seidman supports the proposed partial deferral of Statement 157, Fair Value Measurements, for nonfinancial assets and liabilities
111KB PDF file
10/24/2007 BDO Seidman urges the FASB to table its proposed guidance on accounting for convertible debt securities that may be settled in cash and recommends rethinking and simplifying the accounting for all convertible securities.
44KB PDF File
10/10/2007 BDO Seidman applauds the SEC's efforts to improve financial reporting and urges the CIFR Committee to widen its sights when targeting the factors that cause complexity and unnecessary burdens.
44KB PDF File
9/24/2007 BDO International responds on behalf of our global network to the SEC's proposal to drop the reconciliation requirement for foreign private issuers that submit financial statements prepared in accordance with IFRS as published by the IASB.
835KB PDF file
9/17/2007 BDO Seidman responds to the SEC's proposal for Smaller Company Reporting Company Regulatory Relief and Simplification.
168KB PDF file
7/18/2007 BDO Seidman responds to the SEC's request for additional comment on the definition of "significant deficiency."
32KB PDF file
7/12/2007 BDO Seidman responds to the SEC's request for additional comments on the PCAOB's Auditing Standard No. 5.
35KB PDF file
4/5/2007 BDO Seidman expresses support for a new process of issuing valuation guidance specifically for financial reporting.
34KB PDF File
3/30/2007 BDO Seidman suggests more flexibility in disclosure formats and reduced disclosures for private companies.
61KB PDF File
3/6/2007 BDO Seidman comments on the PCAOB's Rulemaking Docket Matter No. 021 - Proposed Auditing Standard - An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements and Related Other Proposals
83KB PDF File
3/6/2007 BDO Seidman comments on the SEC's Proposed Interpretive Guidance - Management's Report on Internal Control Over Financial Reporting and Proposed Rule Amendments
59KB PDF File
1/31/2007 BDO Seidman suggests some combinations of not-for-profit organizations should be accounted for as mergers of equals, not acquisitions.
36KB PDF File
12/14/2006 BDO Seidman disagrees with the FASB's proposal to treat employee options and restricted stock with dividend rights as participating securities in EPS computations.
130KB PDF File
12/8/2006 BDO Seidman commends the FASB for bringing consistency to accounting for arrangements involving registration payments.
52KB PDF File
5/30/2006 BDO Seidman suggests simpler approach to the FASB's proposed accounting for retirement plans.
42KB PDF File
5/3/2006 BDO Seidman responds to the final report of the SEC's Advisory Committee on Smaller Public Companies.
25KB PDF File
4/11/2006 BDO Seidman comments on the SEC's rule proposal for executive compensation and related party disclosure.
50KB PDF File
11/29/2005 BDO Seidman takes issue with the FASB's proposed change to the computation of earnings per share for mandatorily convertible instruments.
69KB PDF File
10/31/2005 BDO Seidman comments on the FASB's proposal for a dramatic change in the narrow area of accounting and reporting for noncontrolling interests in subsidiaries.
50KB PDF File