Online Comment Letters

As a private organization serving a broad public interest, the FASB has adopted an open decision-making process that permits considerable interaction between the Board and its constituents. This interaction takes many forms. One major part of interaction is in the form of comment letters. Comment letters are received from constituents in response to Discussion Papers, Exposure Drafts, and other discussion documents that are released to the public for comment.

Comment letters, which become an important part of a project's public record, are an important source of information regarding constituents' views on and experiences related to issues raised in a discussion document.

Questions about comment letters should be directed to: sesutay@fasb.org


Select Document Title for List of Letters
Project Document Title Type of Document Issue Date
Accounting for Financial Instruments Accounting for Financial Instruments- Unsolicited Unsolicited 2009-
2014
Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities—Financial Instruments (Topic 825) and Derivatives and Hedging (Topic 815) Exposure Draft May
2010
Supplementary Document—Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities—Impairment Supplementary Document January
2011
Selected Issues about Hedge Accounting Discussion Paper February
2011
Financial Instruments—Credit Losses (Subtopic 825-15) Exposure Draft December
2012
Financial Instruments—Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities Exposure Draft February
2013
Financial Instruments—Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities—Proposed Amendments to the FASB Accounting Standards Codification® Exposure Draft April
2013
Agenda Requests Agenda Requests 2009 Unsolicited March
2009
Agenda Requests 2010 Unsolicited September
2010
Agenda Requests 2011 Unsolicited April
2011
Agenda Requests 2012 Unsolicited July
2012
Agenda Requests 2013 Unsolicited March
2013
Agenda Requests 2014 Unsolicited June
2014
AICPA Private Company Financial Reporting Invitation to Comment June 2006
Balance Sheet (Topic 210) Unsolicited Unsolicited November
2010
Offsetting Exposure Draft January
2011
Unsolicited-2012 Unsolicited September
2012
Clarifying the Scope of Disclosures about Offsetting Assets and Liabilities Exposure Draft November
2012
"Blue-Ribbon" Panel Written Submissions from Constituents BRP-R August
2010
Business Combinations Unsolicited Business Combinations Unsolicited April
2013
Codification Codification- Unsolicited Unsolicited September
2010
Compensation—Retirement Benefits (Topic715) Disclosure about an Employer’s Participation in a Multiemployer Plan-Unsolicited Unsolicited August
2010
Disclosure about an Employer’s Participation in a Multiemployer Plan Exposure Draft September
2010
Pensions-Unsolicited Unsolicited November 2012
Comprehensive Income (Topic 220) Statement of Comprehensive Income Exposure Draft May
2010
Presentation of Comprehensive Income: Reclassifications of Items of Other Comprehensive Income
-Unsolicited
Unsolicited

2011
Deferral of the Effective Date for Amendments to the Presentation of Reclassifications of Items Out of Accumulated Other Comprehensive Income in Accounting Standards Update No. 2011-05 Exposure Draft November
2011
Electronic Constituent Feedback (ECF) Exposure Draft November
2011
Unsolicited Unsolicited 2012
Presentation of Items Reclassified Out of Accumulated Other Comprehensive Income Exposure Draft August
2012
Conceptual Framework Conceptual Framework-Unsolicited Unsolicited 2005-2014
Selected Issues Relating to Assets and Liabilities with Uncertainties Invitation To Comment September
2005
Conceptual Framework for Financial Reporting: Objective of Financial Reporting and Qualitative Characteristics of Decision-Useful Financial Reporting Information Preliminary Views July 2006
Conceptual Framework for Financial Reporting: The Objective of Financial Reporting and Qualitative Characteristics and Constraints of Decision-Useful Financial Reporting Information Exposure Draft May 2008
Conceptual Framework for Financial Reporting: The Reporting Entity Preliminary Views May 2008
The Reporting Entity Exposure Draft March 2010
Conceptual Framework for Financial Reporting: Chapter 8: Notes to Financial Statements Exposure Draft March 2014
Consolidation
(Topic 810)
Accounting and Reporting for Decreases in Ownership of a Subsidiary— a Scope Clarification Exposure Draft August
2009
Amendments to Statement 167 for Certain Investment Funds Exposure Draft December
2009
 
2010 Consolidations Roundtable Roundtable October
2010
Principal versus Agent Analysis Exposure Draft November
2011
Consolidations P&P Unsolicited Unsolicited April
2005
Consolidations Policy and Procedures Consolidated Financial Statements: Policy and Procedures Exposure Draft October
1995
Consolidated Financial Statements: Purpose and Policy Exposure Draft February
1999
Contingencies Contingencies-Unsolicited Unsolicited September
2007
Disclosure of Certain Loss Contingencies—an amendment of FASB Statements No. 5 and 141(R) Exposure Draft June
2008
Contingencies (Topic 450) Disclosure of Certain Loss Contingencies Exposure Draft July
2010
Convergence Convergence- Unsolicited Unsolicited September
2009
Effective Dates and Transition Methods Discussion
Paper
October
2010
Deferred Tax Assets and Liabilities Unsolicited Unsolicited February
2009
Definition of a Public Business Entity An Amendment to the Master Glossary Exposure Draft August
2013
Derivative Instruments and Hedging Activities Derivative Instruments and Hedging Activities-Unsolicited Unsolicited May
2007
Accounting for Hedging Activities—an amendment of FASB Statement No. 133 Exposure Draft June
2008
Derivatives and Hedging (Topic 815) Scope Exception Related to Embedded Credit Derivatives Exposure Draft October 2009
Unsolicited Unsolicited March
2011
Development Stage Entities (Topic 915) Elimination of Certain Financial Reporting Requirements Exposure Draft November
2013
DIG Implementation Issue ISSUE-H17 DIG Issue December
2006
ISSUE-C22 Exception Related to Embedded Credit Derivatives DIG Issue January
2009
Disclosure Framework Disclosure Framework Discussion Paper July
2012
Earnings Per Share Earnings per Share—an amendment of FASB Statement No. 128 Exposure Draft December
2003
Earnings per Share—an amendment of FASB Statement No. 128 Exposure Draft September
2005
Earnings per Share—an amendment of FASB Statement No. 128 Exposure Draft August
2008
EITF Financial Services—Insurance (Topic 944): Consideration of an Insurer’s Accounting for Majority-Owned Investments When Ownership Is through a Separate Account (A Consensus of the FASB Emerging Issues Task Force) EITF090B September
2009
Receivables (Topic 310) Effect of a Loan Modification When the Loan is Part of a Pool That is Accounted for as a Single Asset (A consensus of the FASB Emerging Issues Task Force)



EITF090I
December 2009
Financial Services—Insurance (Topic 944): Accounting for Costs Associated with Acquiring or Renewing Insurance Contracts (A consensus of the FASB Emerging Issues Task Force)


EITF090G
December 2009
Entertainment—Casinos (Topic 924): Casino Base Jackpot Liabilities (A consensus of the FASB Emerging Issues Task Force)

EITF090F
December 2009
Health Care Entities (Topic 954): Presentation of Insurance Claims and Related Insurance Recoveries (A consensus of the FASB Emerging Issues Task Force)

EITF090K
April
2010
Health Care Entities (Topic 954): Measuring Charity for Disclosure (A consensus of the FASB Emerging Issues Task Force)

EITF090L
April
2010
Plan Accounting—Defined Contribution Pension Plans (Topic 962): Reporting Loans to Participants by Defined Contribution Pension Plans (A consensus of the FASB Emerging Issues Task Force)


EITF100C
August
2010
Other Expenses (Topic 720): Fees Paid to the Federal Government by Pharmaceutical Manufacturers (a consensus of the FASB Emerging Issues Task Force)


EITF100D
August 2010
Health Care Entities (Topic 954): Accounting for Legal Costs Associated with Medical Malpractice and Similar Claims (a consensus of the FASB Emerging Issues Task Force)


EITF100F
August 2010
Business Combinations (Topic 805): Disclosure of Supplementary Pro Forma Information for Business Combinations (a consensus of the FASB Emerging Issues Task Force)


EITF100G
October
2010
Intangibles—Goodwill and Other (Topic 350): How the Carrying Amount of a Reporting Unit Should Be Calculated When Performing Step 1 of the Goodwill Impairment Test (a consensus of the FASB Emerging Issues Task Force)



EITF100A
October
2010
Health Care Entities (Topic 954): Disclosure about Net Revenue and Allowance for Doubtful Accounts (a consensus of the FASB Emerging Issues Task Force)


EITF090H
October
2010
Health Care Entities (Topic 954): Presentation and Disclosure of Net Revenue, Provision for Bad Debts, and the Allowance for Doubtful Accounts (a consensus of the FASB Emerging Issues Task Force)



EITF090H2
December
2010
Other Expenses (Topic 720): Fees Paid to the Federal Government by Health Insurers (a consensus of the FASB Emerging Issues Task Force)


EITF100H
December
2010
 
Proposed Accounting Standards Update—Property, Plant, and Equipment (Topic 360): Derecognition of in Substance Real Estate—a Scope Clarification (a consensus of the FASB Emerging Issues Task Force)




EITF-100E
July
2011
Consolidation (Topic 810): Parent’s Accounting for the Cumulative Translation Adjustment upon the Sale or Transfer of a Group of Assets That Is a Nonprofit Activity or a Business within a Consolidated Foreign Entity (a consensus of the FASB Emerging Issues Task Force)




EITF-11A
December
2011
Film Costs
Entertainment —Films (Topic 926): Accounting for Fair Value Information That Arises after the Measurement Date and Its Inclusion in the Impairment Analysis of Unamortized Film Costs (a consensus of the FASB Emerging Issues Task Force)



EITF-12E
April
2012
Statement of Cash Flows (Topic 230): Not-for-Profit Entities: Classification of the Sale of Donated Securities in the Statement of Cash Flows (a consensus of the FASB Emerging Issues Task Force)



EITF-12A
April
2012
Business Combinations (Topic 805): Subsequent Accounting for an Indemnification Asset Recognized at the Acquisition Date as a Result of a Government-Assisted Acquisition of a Financial Institution (a consensus of the FASB Emerging Issues Task Force)



EITF-12C
April
2012
Not-for-Profit Entities (Topic 958): Personnel Services Received from an Affiliate for Which the Affiliate Does Not Seek Compensation (a consensus of the FASB Emerging Issues Task Force)


EITF-12B
 
July
2012
Liabilities (Topic 405): Obligations Resulting from Joint and Several Liability Arrangements (a consensus of the FASB Emerging Issues Task Force)

EITF-12D
July
2012
Consolidation (Topic 810): Accounting for the Difference between the Fair Value of the Assets and the Fair Value of the Liabilities of a Consolidated Collateralized Financing Entity (a consensus of the FASB Emerging Issues Task Force)



EITF-12G
October
2012
Foreign Currency Matters (Topic 830): Parent’s Accounting for the Cumulative Translation Adjustment upon Derecognition of Certain Subsidiaries or Groups of Assets within a Foreign Entity or of an Investment in a Foreign Entity (a consensus of the FASB Emerging Issues Task Force)




EITF-11AR

 
October 2012
Derivatives and Hedging (Topic 815): Inclusion of the Fed Funds Effective Swap Rate (or Overnight Index Swap Rate) as a Benchmark Interest Rate for Hedge Accounting Purposes (a consensus of the FASB Emerging Issues Task Force)


EITF-13A
February
2013
Investments—Equity Method and Joint Ventures (Topic 323): Accounting for Investments in Qualified Affordable Housing Projects (a consensus of the FASB Emerging Issues Task Force)


EITF-13B
April
2013
Income Taxes (Topic 740): Presentation of an Unrecognized Tax Benefit When a Net Operating Loss Carryforward or Tax Credit Carryforward Exists (a consensus of the FASB Emerging Issues Task Force)


EITF-13C
February
2013
Service Concession Arrangements (Topic 853) (a consensus of the FASB Emerging Issues Task Force) EITF-12H July
2013
Receivables—Troubled Debt Restructurings by Creditors (Subtopic 310-40): Reclassification of Collateralized Mortgage Loans upon a Troubled Debt Restructuring (a consensus of the FASB Emerging Issues Task Force) EITF-13E July
2013
Consolidation (Topic 810): Measuring the Financial Liabilities of a Consolidated Collateralized Financing Entity (a consensus of the FASB Emerging Issues Task Force) EITF-12Gr July
2013
Derivatives and Hedging (Topic 815): Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share Is More Akin to Debt or to Equity (a consensus of the FASB Emerging Issues Task Force) EITF-13G October
2013
Compensation—Stock Compensation (Topic 718): Accounting for Share-Based Payments When the Terms of an Award Provide That a Performance Target Could Be Achieved after the Requisite Service Period (a consensus of the FASB Emerging Issues Task Force)  EITF-13D October
2013
Receivables—Troubled Debt Restructurings by Creditors (Subtopic 310-40): Classification of Certain Government-Guaranteed Residential Mortgage Loans upon Foreclosure (a consensus of the FASB Emerging Issues Task Force) EITF-13F January
2014
Business Combinations (Topic 805): Pushdown Accounting (a consensus of the FASB Emerging Issues Task Force) EITF-12F April
2014
Extractive Industries—Oil and Gas (Topic 932) Oil and Gas Reserve Estimation and Disclosures Exposure Draft
September
2009
 
Fair Value Measurement Fair Value Measurements Exposure Draft June
2004
Fair Value Measurements and Disclosures Improving Disclosures about Fair Value Measurements Exposure Draft August
2009
Unsolicited Fair Value Measurements and Disclosures
Unsolicited
 
March 2010
Fair Value Measurements and Disclosures (Topic 820)
 
Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs
 
Exposure Draft June
2010
Fair Value Measurements and Disclosures- Unsolicited Unsolicited October
2011
Fair Value Measurement (Topic 820): Deferral of the Effective Date of Certain Disclosures for Nonpublic Employee Benefit Plans in Update No. 2011-04 Exposure Draft April
2013
FASB and IASB Memorandum of Understanding and Technical Plan Unsolicited Unsolicited December
2010
Financial Accounting Foundation Proposed Changes to Oversight, Structure, and Operations of the FAF, FASB, and GASB Request for Public Comment December
2007
Financial Crisis Advisory Group (FCAG) FCAG Written Submissions from Constituents FCAG-1 March
2009
Financial Instruments (Topic 825) Disclosures about Liquidity Risk and Interest Rate Risk Exposure Draft
 
June
2012
Clarifying the Scope and Applicability of a Particular Disclosure to Nonpublic Entities Exposure Draft January
2013
Financial Instruments Reducing Complexity in Reporting Financial Instruments Invitation to Comment March 2008
Improvements to Recognition and Measurement (FIRM) Unsolicited August
2009
Financial Instruments with Characteristics of Equity Unsolicited-L&E Unsolicited August
2003
Unsolicited- L&E 2007 Unsolicited January
2007
Financial Instruments with Characteristics of Equity Preliminary Views November
2007
Unsolicited Unsolicited March
2009
Financial Statement Presentation Unsolicited Financial Statement Presentation Unsolicited 2007 January
2007
Unsolicited Financial Statement Presentation Unsolicited 2008 January
2008
Preliminary Views on Financial Statement Presentation Discussion Paper October
2008
Unsolicited Financial Statement Presentation Unsolicited March 2010
Introduction to Staff Draft of an Exposure Draft Staff Draft July
2010
FSP Measuring Liabilities under FASB Statement No. 157 FSP FAS 157-c January
2008
Amending the Criteria for Reporting a Discontinued Operation FSP FAS 144-d September
2008
Interim Disclosures about Fair Value of Financial Instruments FSP FAS 107-b and APB 28-a January
2009
Determining Whether a Market Is Not Active and a Transaction Is Not Distressed FSP FAS 157-e March
2009
Recognition and Presentation of Other-Than-Temporary Impairments FSP FAS 115-a, FAS 124-a, and EITF 99-20-b March
2009
Application Guidance for Pass-through Entities and Tax-Exempt Not-for-Profit Entities and Disclosure Modifications for Nonpublic Entities FSP FIN 48-d May
2009
Measuring Liabilities under FASB Statement No. 157 FSP FAS 157-f May
2009
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 FSP FAS 157-g June
2009
GAAP The Hierarchy of Generally Accepted Accounting Principles—a replacement of FASB Statement No. 162 Exposure Draft March
2009
Global Financial Crisis Global Financial Crisis- Unsolicited Unsolicited November
2008
Income Taxes Income Taxes- Unsolicited Unsolicited October
2012
Insurance Contracts Insurance Contracts- Unsolicited Unsolicited 2009-
2010
Insurance Contracts-
Unsolicited
Unsolicited 2011
Insurance Contracts-
Unsolicited
Unsolicited 2012-
2013
Accounting for Insurance Contracts by Insurers and Policyholders Invitation to Comment August
2007
Preliminary Views on Insurance Contracts Discussion Paper September
2010
Insurance Contracts (Topic 834) Insurance Contracts (Topic 834) Exposure Draft June
2013
Insurance Contracts-Unsolicited Unsolicited June
2014
Intangibles—Goodwill and Other (Topic 350) Testing Goodwill for Impairment Exposure Draft April
2011
Electronic Constituent Feedback (ECF) Exposure Draft April
2011
Testing Indefinite-Lived Intangible Assets Exposure Draft January
2012
Interpretation 46(R) Unsolicited Unsolicited May
2008
Reconsideration of FIN 46(R) Consolidation of Variable Interest Entities Exposure Draft September
2008
Unsolicited Unsolicited November 2009
Investment Companies Financial Services—Investment Companies (Topic 946): Amendments to the Scope, Measurement, and Disclosure Requirements Exposure Draft

October
2011
Investment Property Entities Unsolicited Unsolicited September
2010
Real Estate-Investment Property Entities (Topic 973) Exposure Draft October
2011
Leases Leases-Unsolicited Unsolicited October
2007
Leases: Preliminary Views Discussion Paper March
2009
Targeted Outreach Outreach Paper March
2011
Leases (Topic 840) Leases Exposure Draft August
2010
Unsolicited Unsolicited 2011
Unsolicited Unsolicited 2012-2013
Leases (Topic 842) Leases (Topic 842): a revision of the 2010 proposed FASB Accounting Standards Update, Leases (Topic 840) Exposure Draft May
2013
Unsolicited Unsolicited 2013-2014
Loan Loss Disclosures Disclosures about the Credit Quality of Financing Receivables and the Allowance for Credit Losses Exposure Draft June
2009
Non-Profit Consolidations Unsolicited Unsolicited May
2005
Not-for-Profit Not-for-Profit Organizations: Goodwill and Other Intangible Assets Acquired in a Merger or Acquisition—an amendment of FASB Statement No. 142 Exposure Draft October
2006
Not-for-Profit Organizations: Mergers and Acquisitions Exposure Draft October
2006
Not-for-Profit Organizations: Mergers and Acquisitions Request for Additional Comments May
2008
Presentation of Financial Statements (Topic 205) The Liquidation Basis of Accounting Exposure Draft July
2012
Reporting Discontinued Operations Exposure Draft April
2013
Disclosure of Uncertainties about an Entity’s Going Concern Presumption Exposure Draft June
2013
Going Concern Exposure Draft October
2008
Private Company Council (PCC) Derivatives and Hedging (Topic 815): Accounting for Certain Receive-Variable, Pay-Fixed Interest Rate Swaps (a proposal of the Private Company Council) Exposure Draft July
2013
Business Combinations (Topic 805): Accounting for Identifiable Intangible Assets in a Business Combination Exposure Draft July
2013
Intangibles—Goodwill and Other (Topic 350): Accounting for Goodwill Exposure Draft July
2013
Consolidation (Topic 810): Applying Variable Interest Entity Guidance to Common Control Leasing Arrangements (a proposal of the Private Company Council) Exposure Draft August
2013
Private Company Decision-Making Framework A Framework for Evaluating Financial Accounting and Reporting Guidance for Private Companies Discussion Paper July
2012
A Guide for Evaluating Financial Accounting and Reporting for Private Companies Invitation To Comment April
2013
Private Companies Financial Reporting Private Companies Financial Reporting-Unsolicited Unsolicited July
2010
QSPEs Qualifying Special-Purpose Entities and Isolation of Transferred Assets Exposure Draft June
2003
Relating to the Isolation of Transferred Assets in Connection with Its Qualifying Special-Purpose Entity Project to Amend FASB Statement No. 140, Accounting for Transfers and Servicing of Financial As Staff Request for Information April
2004
Unsolicited Unsolicited April
2005
Receivables (Topic 310) Clarifications to Accounting for Troubled Debt Restructurings by Creditors Exposure
Draft
October
2010
Deferral of the Effective Date of Disclosures about Troubled Debt Restructurings in Update No. 2010-20 Exposure Draft December
2010
Repurchase Agreements and Similar Transactions Unsolicited Repurchase Agreements and Similar Transactions Unsolicited November
2012
Research Studies and Reports Research Studies and Reports- Unsolicited Unsolicited November
2011
 
Revenue Recognition Proposal for a New Agenda Project on Issues Related to the Recognition of Revenues and Liabilities Prospectus January
2002
Unsolicited-RR Unsolicited December
2004
Preliminary Views on Revenue Recognition in Contracts with Customers Discussion Paper December
2008
Revenue Recognition (Topic 605) Revenue from Contracts with Customers Exposure Draft July
2010
(Revised)—Revenue Recognition (Topic 605): Revenue from Contracts with Customers Exposure Draft November
2011
Revenue Recognition- Unsolicited Unsolicited 2012-
2014
Simplifications Unsolicited Simplifications Unsolicited 2014
Simplification and Codification Principles-Based Approach to US Standard Setting Proposal October
2002
Statement 140 Amendments Accounting for Transfers of Financial Assets—an amendment of FASB Statement No. 140 Exposure Draft August
2005
Unsolicited Unsolicited June
2006
Accounting for Transfers of Financial Assets—an amendment Exposure Draft September
2008
Subsequent Events (Topic 855) Amendments to Certain Recognition and Disclosure Requirements Exposure Draft December 2009
Subsequent Events Unsolicited Subsequent Events Unsolicited May
2007
Subsequent Events   October
2008
Technical Corrections Rescission of FASB Technical Bulletin No. 01-1, Nullification of EITF Topics No. D-33 and No. D-67, Amendments, and Technical Corrections Exposure Draft March
2009
Technical Corrections Exposure Draft October
2011
Technical Corrections and Improvements Related to Glossary Terms Exposure Draft May
2013
Technical Corrections- Unsolicited Unsolicited November
2013
Transfers and Servicing (Topic 860) Reconsideration of Effective Control for Repurchase Agreements Exposure Draft November
2010
Effective Control for Transfers with Forward Agreements to Repurchase Assets and Accounting for Repurchase Financings Exposure Draft January
2013
Unsolicited Comment Letters- Post Issuance Unsolicited Comment Letters- Post Issuance Unsolicited Beginning in November
2010