Financial Crisis Advisory Group (FCAG)

FCAG Written Submissions from Constituents

Comment Letter Summary

Comment Letters

The Financial Crisis Advisory Group (FCAG) is seeking written input from constituents in the form of responses to the following set of questions, to assist the FCAG in discussing accounting and reporting matters related to the financial crisis and making recommendations thereon to the IASB and the FASB:

  1. From your perspective, where has general purpose financial reporting helped identify issues of concern during the financial crisis? Where has it not helped, or even possibly created unnecessary concerns? Please be as specific as possible in your answers.
     
  2. If prudential regulators were to require 'through-the-cycle' or 'dynamic' loan provisions that differ from the current IFRS or US GAAP requirements, how should general purpose financial statements best reflect the difference: (1) recognition in profit or loss (earnings); (2) recognition in other comprehensive income; (3) appropriation of equity outside of comprehensive income; (4) footnote disclosure only; (5) some other means; or (6) not at all? Please explain how your answer would promote transparency for investors and other resource providers.
     
  3. Some FCAG members have indicated that they believe issues surrounding accounting for off-balance items such as securitizations and other structured entities have been far more contributory to the financial crisis than issues surrounding fair value (including mark-to-market) accounting. Do you agree, and how can we best improve IFRS and US GAAP in that area?
     
  4. Most constituents agree that the current mixed attributes model for accounting and reporting of financial instruments under IFRS and US GAAP is overly complex and otherwise suboptimal. Some constituents (mainly investors) support reporting all financial instruments at fair value. Others support a refined mixed attributes model. Which approach do you support and why? If you support a refined mixed attributes model, what should that look like, and why, and do you view that as an interim step toward full fair value or as an end goal? Whichever approach you support, what improvements, if any, to fair value accounting do you believe are essential prerequisites to your end goal?
     
  5. What criteria should accounting standard-setters consider in balancing the need for resolving an 'emergency issue' on a timely basis and the need for active engagement from constituents through due process to help ensure high quality standards that are broadly accepted?
     
  6. Are there financial crisis-related issues that the IASB or the FASB have indicated they will be addressing that you believe are better addressed in combination with, or alternatively by, other organizations? If so, which issues and why, and which organizations?
     
  7. Is there any other input that you'd like to convey to the FCAG?

If you or your organization would like to submit your responses to the questions, please email them to Adam Van Eperen, ajvaneperen@fasb.org, no later than Thursday, April 2, 2009. All submissions will be considered public and will be posted to this webpage for public viewing. A summary of the responses received through April 2 will also be prepared and distributed to FCAG members and official observers, and will be included as part of the observer notes (publicly available meeting handout) for the FCAG’s next meeting, on Monday April 20, in London. To facilitate the FASB and IASB staffs' ability to read and summarize the submissions, we ask that you please try to be as succinct as possible in your responses to the questions.