PwC comment letters
PwC responses to proposals or concept releases issued by various standard setter organizations and regulators
PwC comment letter (AICPA)
PwC Comments on Proposed AICPA Financial Reporting Framework for Small- and Medium-Sized Entities
1/29/13 | Assurance servicesPwC 2012 SEC Comment Letter Trends for Industry Sectors
1/29/13 | Assurance servicesPwC comment letter (FASB)
PwC Comments on Proposed ASU: Financial Instruments—Overall (Subtopic 825-10)—Recognition and Measurement of Financial Assets and Financial Liabilities and the Proposed Amendments to the FASB Accounting Standards Codification5/15/13 | Assurance services
PwC supports the FASB’s proposed comprehensive framework for classifying financial instruments, which is not dependent on legal form. We agree that the primary drivers for how financial assets are classified and measured should be a company's business model for managing its financial assets, as well as the cash flow characteristics of the instruments. The accounting model should faithfully portray the economic consequences of transactions in the context of a company's business strategies and the nature of those financial instruments.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Clarification of Acceptable Methods of Depreciation and Amortization4/15/13 | Global accounting consulting services
PwC agrees with the principle of the proposed amendments although we are not convinced that the amendments are necessary.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Novation of Derivatives and Continuation of Hedge Accounting4/2/13 | Global accounting consulting services
PwC supports the board’s efforts in clarifying whether an entity is required to discontinue hedge accounting when an over-the-counter (OTC) derivative is novated to a central counterparty (CCP) as required by law or regulation. We also appreciate the board’s responsiveness in addressing this urgent issue in a pragmatic way, as requiring entities to treat such novations as a discontinuance of hedge accounting would not provide useful information to investors.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Transfers and Servicing (Topic 860): Effective Control for Transfers with Forward Agreements to Repurchase Assets and Accounting for Repurchase Financings3/29/13 | Assurance services
PwC fully supports the Board’s continuing efforts to respond in a timely manner to stakeholder concerns over elements of the transfers of financial assets accounting model.
PwC comment letter (IASB)
PwC Comments on Exposure draft: Classification and Measurement: Limited Amendments to IFRS 93/28/13 | Global accounting consulting services
PwC agrees with the board’s objectives to amend IFRS 9 and commend the board on their progress in achieving those objectives. The letter includes key comments that we would like to raise with the board.
PwC comment letter (IASB)
PwC Comments on Tentative agenda decision: IAS 10 Events after the reporting period—Reissuing previously issued financial statements3/19/13 | Global accounting consulting services
Following consultation with members of the PwC network of firms, this response summarizes the views of member firms who commented on the tentative agenda decision, published in the January 2013 edition of IFRIC Update.
PwC comment letter (AICPA)
PwC Comments on Proposed AICPA Financial Reporting Framework for Small- and Medium-Sized Entities1/29/13 | Assurance services
PwC fully supports efforts to enhance financial reporting for private companies, and believes that the most appropriate way to achieve meaningful change for private company stakeholders is through the collaborative efforts of the recently established Private Company Council (PCC) and the FASB. However, should the AICPA decide to issue this new non-GAAP framework, our comment letter provides observations and recommendations on changes the AIPCA should make to minimize confusion and enhance clarity. ...
PwC comment letter (SEC)
SEC comment letter and reporting trends for the power and utilities industry1/28/13 | Power & utilities
To assist power and utility company reporting entities preparing their year-end financial statements, PwC's US Power and Utilities practice have published the 2012 SEC comment letter trends for the power and utilities industry, which is based on our review of industry related comment letters on Form 10-Ks and Form 10-Qs published in 2012.
PwC comment letter (SEC)
Automotive sector 2012 SEC comment letter trends1/24/13 | Automotive
PwC has prepared this report to assist management teams identify and understand the areas most frequently commented on by the SEC. The information summarized in this report is based on comment letters issued to companies in the automotive sector and closed by the SEC from October 1, 2011, to October 31, 2012.
PwC comment letter (SEC)
Retail & Consumer sector 2012 SEC comment letter trends1/24/13 | Retail & consumer
PwC has issued a summary document of comment letter trends and considerations for 2012 year-end financial reporting for retail and consumer companies.The information summarized within this publication is based on comment letters published by the SEC staff between October 1, 2011 and October 1, 2012 related to R&C registrants. Areas reviewed include management discussion and analysis, controls and procedures, revenue recognition, and much more
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Clarifying the Scope of Disclosures about Offsetting Assets and Liabilities1/7/13 | Assurance services
PwC agrees with the proposed change to limit the disclosures to derivatives, repurchase agreements and reverse repurchase agreements, and securities borrowing and securities lending transactions that are either offset or subject to a master netting arrangement or similar agreement.
PwC comment letter (IASB)
PwC Comments on IASB Request for Information: IFRS for SMEs1/3/13 | Global accounting consulting services
PwC global network of firms submitted comments on the IASB's request for information on IFRS for SMEs. The comments provided have been grouped into six broad categories to simplify our response and to avoid repetition. The Firm comments specifically on the scope of the SME standard, convergence with IFRSs, income taxes, options, convergence with the EU directives and the use of additional IASB guidance for SMEs.
PwC comment letter (AICPA)
PwC Comments on Omnibus Proposal of the AICPA Professional Ethics Division - September 19, 201212/11/12 | Assurance services
PwC supports the PEEC's stated objective of clarifying the circumstances under which the AICPA Code of Professional Conduct applies to services provided by its members. PwC recommends that prior to adopting its proposal, the PEEC should further consider three things: (1) whether the PEEC's proposed revision to the definition of professional services will have the unintended effect of sweeping in services that have no connection with or relationship to the practice of accountancy; ...
PwC comment letter (SEC)
Review of 2012 SEC comment letter trends for energy companies12/10/12 | Energy & mining
This publication provides an analysis of SEC comment letters issued to registrants across the energy value chain, including exploration and production, midstream, downstream, drillers, oilfield services, and integrated energy companies.
PwC comment letter (SEC)
Industrial Products sector 2012 SEC comment letter trends12/3/12 | Industrial products
PwC has issued a summary document of comment letter trends and considerations for year-end financial reporting for industrial products and services companies. Areas reviewed include management discussion and analysis, goodwill impairment, revenue recognition, and much more.
PwC comment letter (FASB)
PwC Comments on Invitation to Comment: Disclosure Framework11/29/12 | Assurance services
PwC encourages the Board to continue its outreach to investors and other stakeholders as it decides which alternatives to proceed with and develops them into a proposal. PwC generally supports the Board's effort to improve the relevance and comparability of financial reporting by developing a framework for setting disclosure requirements.
PwC comment letter (FASB)
PwC Comments on Invitation to Comment: Private Company Decision-Making Framework - A Framework for Evaluating Financial Accounting and Reporting Guidance for Private Companies10/30/12 | Assurance services
PwC generally believes that the draft framework identifies the appropriate matters to consider when determining whether a modification is appropriate. It identifies the significant differentiating factors that could support financial reporting differences between public and private companies.
PwC comment letter (FASB)
PwC Comments on Proposed ASU, Presentation of Items Reclassified Out of Accumulated Other Comprehensive Income10/16/12 | Assurance services
PwC supports the proposal to provide information about the impact of reclassifications from accumulated other comprehensive income to net income in a single footnote. Most of the information to be disclosed is already included elsewhere in the financial statements. Consolidating it and providing a roadmap to the related disclosures will provide users with improved information without the operational challenges and costs that would have resulted from requiring separate presentation on the face of the income statement of the effects of the reclassifications on individual line items, particularly when such information is not readily available.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: The Liquidation Basis of Accounting10/8/12 | Assurance services
PwC suggests enhancements to the proposed guidance in the event that others believe it will be helpful to preparers and financial statement users and will improve consistency as to when and how to prepare financial statements using the liquidation basis of accounting.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Disclosures about Liquidity Risk and Interest Rate Risk - Financial Instruments (Topic 825)9/25/12 | Assurance services
PwC agrees that improved disclosures about liquidity and interest rate risks could provide a deeper understanding of an entity's risk profile. While the Firm encourages the Board to continue its outreach to analysts and preparers as it further develops the proposed disclosures, it offers a number of recommendations for the Board's consideration.
PwC comment letter (IASB)
PwC Comments on Draft Interpretation DI/2012/1: Levies charged by public authorities on entities that operate in a specific market9/12/12 | Global accounting consulting services
The PwC network global network of firms believes that the application of the conclusions in the draft interpretation will result in accounting that does not reflect the economic substance of many levies.
PwC comment letter (IASB)
PwC Comments to the IASB on Tentative Agenda Decision: IAS 19 , Employee benefits - Accounting for contribution-based promises7/30/12 | Global accounting consulting services
PwC global network of firms supports the Interpretations Committee's decision that the accounting for employee benefit plans with a promised return on contributions or notional contributions explored in the Draft IFRIC should be further considered.
PwC comment letter (PCAOB)
PwC Comments on Proposed Auditing Standard on Related Parties and Related Amendments to PCAOB Auditing Standards5/31/12 | Assurance services
PwC generally supports the proposals and believes they will heighten the auditor's focus on the potential for material misstatement, particularly material misstatement due to fraud, arising from relationships and transactions with related parties, significant unusual transactions, and financial relationships and transactions with executive officers.
PwC comment letter (PCAOB)
PwC Comments on Proposed Amendments to Conform the PCAOB's Rules and Forms to the Dodd-Frank Act and Make Certain Updates and Clarifications5/8/12 | Assurance services
PwC believes that the audits of brokers and dealers should be conducted in accordance with PCAOB auditing and attestation standards once the SEC adopts Rule 17a-5 and, therefore, supports the changes to the Board's rules to reflect its pending jurisdiction over the auditors of brokers and dealers.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Testing Indefinite-Lived Intangible Assets4/30/12 | Assurance services
PwC generally supports the use of a qualitative assessment that could result in an entity not having to measure the fair value of an indefinite-lived intangible asset in certain circumstances, such as when the asset's recently calculated fair value substantially exceeded its carrying amount and no significant adverse changes have since occurred.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Transition Guidance - Proposed amendments to IFRS 104/12/12 | Global accounting consulting services
PwC global network of firms agrees with the relief provided in the exposure draft with regards to the transition guidance in IFRS 10. However, the firm believes that the effect of the BoardÆs proposed relief is complicated to implement in practice. ...
PwC comment letter (FASB)
PwC Comments on FASB and IASB Exposure Draft - Revenue from Contracts with Customers3/14/12 | Assurance services
PwC agrees with the boards' objectives and supports a single revenue recognition model that provides clearer and more consistent guidance. PwC supports the overall project. There are, however, areas where the concepts could be more clearly articulated, might be challenging to apply, or do not appear cost-beneficial. In the letter, these areas are explained in the firm's responses to the boards' questions, including responses to the FASB's questions on the US GAAP consequential amendments.
PwC comment letter (PCAOB)
PwC Comments on Proposed Auditing Standard Related to Communications With Audit Committees; Related Amendments to PCAOB Standards; and Transitional Amendments to AU Sec. 3802/29/12 | Assurance services
PwC commends the Board for issuing a re-proposal of the proposed standard and appreciate the Board's responsiveness in considering, addressing and providing feedback with respect to comments received on the original proposal. In the letter, PwC respectfully offers some suggestions that it believes will further improve the proposal.
PwC comment letter (FASB)
PwC Comments on Proposed ASU, Consolidation (Topic 810) - Principal versus Agent Analysis2/16/12 | Assurance services
PwC supports the FASB and IASB's efforts to develop an approach for assessing whether a decision maker is using its decision-making authority in a principal or an agent capacity. However, consolidation is only one of two important elements needed to achieve convergence in the recognition of financial assets and liabilities by financial entities. PwC's preference is for the Boards to work together to reach a converged solution for all aspects of recognition, including considering their respective guidance for derecognition of financial instruments.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Financial Services - Investment Companies (Topic 946)2/16/12 | Assurance services
PwC is concerned about the significant differences between the Boards' respective proposals. For example, the Boards' differ in their proposed treatment of a controlling financial interest in an investment company held by a non-investment company parent. PwC believes that such significant differences should be eliminated in order to achieve a truly converged standard.
PwC comment letter (FASB)
PwC Comments on Proposed ASU, Real Estate - Investment Property Entities (Topic 973)2/16/12 | Assurance services
PwC does not believe that measuring all real estate investments at fair value will necessarily yield better reporting for all types of investors. However, we do believe that fair value for entities that are fundamentally investing entities, as opposed to operating entities, would provide more relevant information to users of financial statements. Further, even among investing entities that account for their real estate investments at fair value, significant diversity in application exists with respect to presentation, measurement, consolidation and disclosure.
PwC comment letter (SEC)
PwC Comments on the SEC's Revisions to Auditor Independence Requirements1/31/12 | Assurance services
PwC provides its perspective on the rules to be reviewed in accordance with the requirements of the Regulatory Flexibility Act. PwC's comments are focused on auditor independence requirements approved by the SEC in November 2000, highlighting areas where the firm believes those rules may have a detrimental impact on small companies, investors and the U.S. capital markets.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Investment Entities1/12/12 | Global accounting consulting services
PwC global network of firms welcomes the IASB's approach to provide differentiated fair value reporting for qualifying investment entities. The Firm, however, is concerned that there are significant differences between the IASB and FASB's respective proposals. The Firm believes that the Boards' differing approaches to the treatment of a controlling financial interest in an investment entity by a non-investment entity parent should be eliminated.
PwC comment letter (PCAOB)
PwC Comments on Improving Transparency of Audits: Proposed Amendments to PCAOB Auditing Standards and Form 21/10/12 | Assurance services
Although supportive of the Board's objective, PwC is not convinced that these proposals will provide meaningful information to investors and other users of audit reports and enhance audit quality. PwC also believes that concerns remain about the potential litigation impact on the persons identified in the report. However, in the interest of promoting transparency in audits, PwC supports the identification of the engagement partner in Form 2.
PwC comment letter (FASB)
PwC Comments on FAF's Plan to Establish the Private Company Standards Improvement Council12/21/11 | Assurance services
PwC strongly supports FAF's plan to create the Private Company Standards Improvement Council and to maintain FASB as the sole authoritative standard-setting board for public and private companies. The Foundation's plan is the appropriate response to the private company financial reporting community's concerns about the relevance, growing complexity, and costs of compliance associated with U.S. GAAP.
PwC comment letter (PCAOB)
PwC Comments on Concept Release on Auditor Independence and Audit Firm Rotation12/15/11 | Assurance services
PwC does not support mandatory audit firm rotation, a possible new requirement the Concept Release explores in-depth. There does not appear to be evidence of a correlation between extended audit tenure and diminished audit quality. PwC supports considering other alternatives to further enhance audit quality, including with respect to auditor independence, objectivity and professional skepticism, which build on reforms made thus far and focus on enhancing auditor and audit committee communications and disclosures.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Technical Corrections12/13/11 | Assurance services
PwC supports the Board's efforts to clarify the Codification, correct unintended application of guidance, and conform the use of the term fair value throughout the Codification. PwC generally agrees with the proposed changes and believes they meet the project's objective to improve the Codification. PwC provides some observations on several amendments that it believes require further consideration or clarification.
PwC comment letter (IASB)
PwC Comments on Request for views: Agenda Consultation 201112/13/11 | Global accounting consulting services
PwC global network of firms provides detailed responses to the questions included in the Agenda Consultation. The Firm also notes some of the broader issues that it believes the Trustees and the IASB should consider when establishing the agenda of the IASB.
PwC comment letter (IASB)
PwC Comments on Draft IFRS for SMEs Interpretation of "Undue Cost or Effort" and "Impracticable" (General, Issue 2)11/29/11 | Global accounting consulting services
PwC global network of firms strongly believes that the Implementation Group should not issue a Q&A that addresses the interpretation of "undue cost or effort" and/or "impracticable." The Firm believes that the SMEIG should not address through Q&As issues that might be relevant to full IFRS. The Firm notes that the SMEIG might use the "basis for conclusions" in the Q&As to limit the scope of the non-mandatory guidance, but there remains a danger that the Q&As might be considered in the interpretation of full IFRS, particularly in areas in which there is no guidance in full IFRS.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Deferral of the Effective Date for Amendments to the Presentation of Reclassifications of Items Out of Accumulated Other Comprehensive Income in ASU 2011-0511/21/11 | Assurance services
PwC supports the FASB's decision to indefinitely defer the requirement in ASU 2011-05 to measure and present reclassifications from accumulated other comprehensive income to net income by income statement line item in net income and also in other comprehensive income.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Improvements to International Financial Reporting Standards10/26/11 | Global accounting consulting services
PwC global network of firms agrees in in principle with the proposed improvements. PwC global network provides its responses to the specific questions in the proposal, including suggestions to clarify the proposed wording of several of the proposed improvements.
PwC comment letter (IASB)
PwC Comments on Tentative agenda decision: IAS 12 Income taxes - rebuttable presumption to determine the manner of recovery10/26/11 | Global accounting consulting services
PwC global network of firms does not support the tentative agenda decision as drafted. The firm supports the committee's conclusion that this item should not be taken onto the agenda. The firm also supports the committee's conclusion that the presumption in paragraph 51C of IAS 12,'Income taxes can be rebutted in other circumstances, which is based on the guidance in IAS 12. However, the final two sentences of the tentative agenda decision contain an interpretation of IAS 12 that is not supported by the guidance in the standard.
PwC comment letter (IFAC)
PwC Comments on IAASB Consultation Paper: Enhancing the Value of Auditor Reporting: Exploring Options for Change10/26/11 | Global accounting consulting services
PwC global network of firms believes that the time is right to significantly enhance auditor reporting. Valuable enhancements can be made now that move us some way to achieving the goal of more informative and valuable auditor reporting. As solutions are developed, it is critical that there be active, continuous and open dialogue amongst auditing standard setters, regulators, users and other stakeholders. PwC global network urges the IAASB to work in collaboration with the PCAOB in relation to their respective consultation papers to develop solutions that work globally.
PwC comment letter (IASB)
PwC Comments on Exposure draft: Mandatory Effective Date of IFRS 910/26/11 | Global accounting consulting services
PwC global network of firms welcomes the decision of the Board to delay the mandatory effective date of IFRS 9. However, PwC global network questions whether the proposed date of January 1, 2015, will be enough of a delay. The firm believes that the Board should allow for a period of at least 18 months from the date of the finalizing IFRS 9 and the insurance project to the first comparative period covered by the new standard. Given that it does not appear that these projects will be completed before the second half of 2012, PwC global network recommends that the Board considers whether the proposed date is realistic in view of the most likely time line for the projects.
PwC comment letter (IASB)
PwC Comments on Tentative agenda decision: IAS 12 Income taxes - Corporate wrapper10/26/11 | Global accounting consulting services
PwC Global Network of Firms does not support the tentative agenda decision as drafted. The Firm supports the Committee's conclusion that this item should not be taken onto the agenda because it raises fundamental questions about the principles in IAS 12 that should be addressed by the IASB.
PwC comment letter (PCAOB)
PwC Comments on Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements and Related Amendments to PCAOB Standards10/4/11 | Assurance services
PwC commends the PCAOB for its outreach to investors and others as a basis for developing the Concept Release and for its continued outreach via the public roundtable held on September 15, 2011. Results of that outreach clearly call for changes to the auditor's reporting model to increase its transparency and relevance. PwC believes the time is right for changes to the auditor's reporting model, and further agree with the Board that any change cannot compromise audit quality.
PwC comment letter (IFAC)
PwC Comments on Proposed ISAE 3000 (Revised), Assurance Engagements Other Than Audits or Reviews of Historical Financial Information9/15/11 | Global accounting consulting services
PwC global network of firms believes that the proposed standard provides a strong basis for the performance of all assurance engagements and will facilitate consistent high quality engagements, capable of being supplemented by clearly tailored topic-specific ISAEs as required, in response to the needs of users. PwC global network also believes that the revisions to the requirements and application material to better articulate the defining characteristics of a limited assurance engagement, together with the principles and differences between attestation and direct engagements, are useful.
PwC comment letter (AICPA)
PwC Comments on Proposed Principles and Criteria for XBRL-Formatted Information8/11/11 | Assurance services
PwC supports the AICPA Assurance Services Executive Committee's decision to develop a set of principles and criteria to evaluate information formatted in XBRL. PwC recommends, however, before finalizing the principles and criteria, the AICPA discuss with the SEC whether the SEC would accept examination reports using the principles and criteria given that they are not meant to be the criteria for evaluating compliance with SEC rules, and also evaluate whether additional feedback from preparers and users should be obtained. PwC also suggested some changes to the principles and criteria.
PwC comment letter (IASB)
PwC Comments on the IFRS Foundation Trustees' Strategy Review8/4/11 | Global accounting consulting services
PwC Global Network of Firms (1) provides some overall observations on what the Firm considers to be important issues connected with the IFRS Foundation Trustees' Strategy Review and (2) shares its views on the specific principles and recommendations proposed by the Trustees with respect to the organization's (1) mission, (2) governance, (3) due process, and (4) funding.
PwC comment letter (SEC)
PwC Comments on SEC Staff Paper: Exploring a Possible Method of Incorporation of IFRS8/4/11 | Assurance services
PwC commends the SEC staff for their continued, thorough evaluation of whether, when and how IFRS should be incorporated into the US financial reporting system. PwC continues to support a vision of a single set of high-quality, global accounting standards that are consistently applied, and the Firm believes that IFRS provides the best basis for achieving this vision. In PwC's opinion, further improvements are still required in the quality of accounting standards and more work is required by standard setters, preparers, auditors, and key capital market securities regulators to improve the consistency of IFRS application. PwC also believes that the endorsement approach described in the staff paper is a fair starting point from which to...
PwC comment letter (IASB)
PwC Comments on Draft Q&As: IFRS for SMEs Section 1 - Issues 3 and 46/21/11 | Global accounting consulting services
PwC network of firms believes that the SMEIG should not address through Q&As issues that might be relevant to full IFRS. There is a danger that the Q&As, although not mandatory and specific to the IFRS for SMEs (the standard), might be applied in the interpretation of full IFRS. PwC does not believe this to be appropriate, and believes Q&As issued by the SMEIG should be restricted to issues that affect the IFRS for SMEs only.
PwC comment letter (IASB)
PwC Comments on IAS 19 Defined Contribution Plans with Vesting Conditions6/21/11 | Global accounting consulting services
PwC network of firms expressed concern that the draft agenda decision does not take into account the wide range of conditions that can arise in employee benefit plans and as a result presents a conclusion that is too definitive and might lead to inappropriate accounting.
PwC comment letter (AICPA)
PwC Comments on AICPA Professional Ethics Division Omnibus Proposal - Interpretations and Rulings6/7/11 | Assurance services
PwC is generally in agreement with most of the proposals in the exposure draft and provides some observations that the Firm believes would improve the proposal. With respect to the proposed definition of "confidential client information" in ET Section 92, as well as the proposed revisions to Ethics Ruling No. 2, "Distribution of Client Information to Trade Associations," under Rule 301, PwC believes that the proposed revisions create additional compliance parameters, yet PEEC has provided no evidence of concerns raised by clients or issues or breaches that client companies have raised regarding either violations of the current guidance, or its being inadequate as currently written. PwC, therefore, recommends that the PEEC obtain...
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Testing Goodwill for Impairment6/6/11 | Assurance services
PwC expresses its support, in principle, of the use of some form of a qualitative assessment that could result in an entity not having to measure fair value of a reporting unit in certain circumstances. PwC believes the proposed update will be more cost effective than current guidance when a reporting unit's fair value substantially exceeded its carrying amount in a prior period and no significant adverse changes have since occurred. PwC believes, however, that in other situations, the proposed update may limit potential cost savings and create implementation challenges. Consequently, the Firm believes a modification to the existing guidance that expands the ability to carry forward the fair value determination of a reporting unit could...
PwC comment letter (FASB)
PwC Comments on Invitation to Comment: Selected Issues about Hedge Accounting (Including IASB Exposure Draft, Hedge Accounting)4/26/11 | Assurance services
In view of the difficulties that practice has experienced in applying hedge accounting, PwC supports the FASB and IASB's overall efforts to simplify accounting for hedging activities and to improve transparency for users of financial statements. The firm is supportive of many of the proposed amendments to hedge accounting in the FASB's proposed ASU, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities, issued in May 2010. PwC expects that several of the FASB's proposed amendments will help reduce the complexity of qualifying for hedge accounting and improve the consistency and comparability of financial reporting.
PwC comment letter (IFAC)
PwC Comments on IAASB Consultation Paper: Proposed IAASB Strategy and Work Program for 2012-20144/18/11 | Global accounting consulting services
In developing the IAASB strategy and work program for 2012-2014, PwC reflected on a number of factors that the Firm believes need to be considered beyond the relative priorities of possible projects alone. A number of developments and events will have a direct bearing on the expectations of stakeholders of the IAASB's activities and the respective priorities of both ongoing and future projects. PwC believes the IAASB will need to be suitably flexible as the outcome of some of these factors is not yet determined and, once known, may impact decisions on which, and how many, projects should be undertaken.
PwC comment letter (IFAC)
PwC Comments on Proposed ISRS 4410, Compilation Engagements (Revised)4/18/11 | Global accounting consulting services
PwC believes that the revision of extant ISRS 4410, and adoption of the clarity drafting guidelines, will serve to enhance understanding, of both users and practitioners, of the nature and scope of compilation engagements and of the distinguishing features of such engagements, as compared to other assurance type engagements. PwC supports the objective and overall work effort described in the proposed standard. The Firm also agrees with the principles on which the requirements, that describe the practitioner's work effort, are based.
PwC comment letter (FASB)
PwC Comments on IASB/FASB Supplementary Document: Accounting for Financial Instruments: Impairment4/4/11 | Global accounting consulting services
Consistent with the Firm's comment letters on the original IASB exposure draft and the FASB proposed ASU, PwC supports an expected loss approach to accounting for the impairment of financial assets carried at amortized cost. PwC believes the impairment model should: (i) measure credit losses consistent with current market expectations regarding collectability, and (ii) recognize the expected losses over the life of the instrument in a manner consistent with its pricing. The Firm believes this better reflects the economics of lending transactions than recognizing lifetime expected losses immediately. While preferring the conceptual merits of such a model, PwC acknowledges the operational and pragmatic concerns that exist and are...
PwC comment letter (IFAC)
PwC Comments on Proposed IAPS 1000, Special Considerations in Auditing Complex Financial Instruments3/29/11 | Global accounting consulting services
PwC supports the proposed IAPS and its practical guidance given the prevalence of fair value accounting and the global economic environment, which continues to present challenges in the valuation of complex financial instruments and disclosures about risk and uncertainties. PwC supports the detailed audit considerations guidance in the proposed IAPS and believes that it will provide a useful source of guidance for those auditors with less experience in auditing complex financial instruments. PwC believes that there are some areas in the draft which interpret requirements and guidance in the ISAs in a manner that the firm is not convinced is appropriate, and could result in unnecessary work effort in some circumstances or may be...
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Hedge Accounting3/15/11 | Global accounting consulting services
PwC believes that overall the proposals in the exposure draft make significant progress towards aligning the accounting more closely with risk management, establishing a more principles-based approach and addressing many of the inconsistencies and weaknesses in IAS 39. PwC is particularly supportive of eliminating the current bright line for effectiveness testing, allowing effectiveness to be assessed on a qualitative basis, expanding the ability to hedge component risks to non-financial items, and allowing hedge accounting to be applied to groups of items that include offsetting positions. PwC believes, however, that there are some areas where changes to the proposed standard should be considered to better address the project's objective.
PwC comment letter (IASB)
PwC Comments on IFRS Foundation Trustees' Review of Strategy3/3/11 | Global accounting consulting services
PwC global network notes the potential for overlap between the Trustees' strategy review and the Monitoring Board's review of governance, while applauding recent announcements around enhanced coordination of the two reviews. Overall, the PwC network continues to support the existing three-tier structure (Trustees, Monitoring Board, and the IASB), but suggests greater clarity in the roles and responsibilities of the Monitoring Board and the Trustees. The PwC network also emphasizes that the organizationÆs structure needs to be scalable to meet the growing need for interpretation and application guidance with the continued adoption of IFRS throughout the world and the high volume of new standards expected in the next year.
PwC comment letter (PCAOB)
PwC Comments on Proposal for Allocation of the Board's Accounting Support Fee Among Issuers, Brokers, & Dealers, and Other Amendments to the Board's Funding Rules2/15/11 | Assurance services
PwC believes that, consistent with the existing rule, the issuer, rather than the registered public accounting firm as is proposed, should be responsible for submitting notice to the PCAOB when a registered public accounting firm has signed an unqualified opinion or issued a consent to reissue a previously issued report in special circumstances when the issuer has outstanding a past-due share of the accounting support fee. If adopted as proposed, PwC asks that the Board explain its rationale for this change since its purpose is not clear.
PwC comment letter (FASB)
PwC Comments on Request for Views/Discussion Paper: Effective Dates and Transition Methods1/31/11 | Global accounting consulting services
PwC believes a single effective date approach should be adopted with an unrestricted early adoption option of any or all of the standards available to all companies. This is especially important for first-time adopters of IFRS. Based on the firm's discussions with clients that are most affected and assuming final standards on the priority projects are issued by June 2011, PwC believes the effective date should be no earlier than periods beginning 1 January 2015. This date would allow companies sufficient lead time to implement the new standards correctly the first time, reduce costs, improve operations and minimize risk.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Reconsideration of Effective Control for Repurchase Agreements (Transfers and Servicing - Topic 860)1/18/11 | Assurance services
PwC supports the Board's proposal to modify the criteria for when repurchase agreements, including reverse repurchase agreements (collectively referred as "repurchase agreements) and other agreements that both entitle and obligate a transferor to repurchase or redeem financial assets before their maturity, would be accounted for as a sale (or secured borrowing) upon transfer of such assets. In the letter, the firm provides responses to the Board's specific questions.
PwC comment letter (IASB)
PwC Comments on Tentative agenda decision: IAS 37 Provisions, Contingent Liabilities and Contingent Assets - Inclusion of own credit risk in the discount rate1/11/11 | Global accounting consulting services
PwC does not agree with the decision to defer consideration of this issue until the IASB's project to replace the provisions standard (IAS 37), or with the reasons given for that decision. PwC is aware of some differences of view on this issue, and believes there may be limited diversity in practice today, but the Firm is concerned that the agenda decision might result in further diversity that does not exist today.
PwC comment letter (SEC)
PwC Comments on Proposed Rules for Implementing Whistleblower Provisions of Section 21F of the Securities Exchange Act of 193412/30/10 | Assurance services
PwC recommends that the final rules require, as a condition of eligibility for an award, that the whistleblower report the information through its entity's internal reporting mechanism at least concurrently with reporting the information to the SEC. In addition, PwC believes that accounting firm employees should be excluded from eligibility for whistleblower awards, not just pursuant to the limited exclusions identified in the proposed rules. PwC believes the proposed broader scope of the exclusion is consistent with the functions of accounting firms and that whistleblower reports by accounting firm personnel are appropriately channeled through existing legal and professional requirements, as well as through internal accounting firm...
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Deferral of the Effective Date of Disclosures about Troubled Debt Restructurings in Update No. 2010-2012/23/10 | Assurance services
PwC supports the FASB's proposal to delay the effective date of the additional disclosures about troubled debt restructurings in ASU 2010-20 until it completes deliberations in its separate project to clarify what constitutes a troubled debt restructuring. The firm believes that disclosures about restructurings designed to mitigate or avoid credit losses are important to users of the financial statements. PwC, however, shares the concerns raised by the Board's constituents that implementing the new troubled debt restructuring (TDR) disclosure requirements in ASU 2010-20 in one reporting period, shortly followed by the adoption of a change in the guidance on what constitutes a TDR, would unnecessarily burden preparers and could confuse...
PwC comment letter (FASB)
PwC Comments on Proposed ASU, Clarifications to Accounting for Troubled Debt Restructurings by Creditors12/14/10 | Assurance services
PwC recommends that the troubled debt restructuring recognition and measurement model also be considered in the Board's deliberations on the financial instruments project. The firm believes it is important to consider the financial instruments accounting model, including the recognition and measurement for troubled debt restructurings, holistically in order to achieve a consistent framework. PwC also recommends that the Board modify the troubled debt restructuring measurement guidance such that the relevant impairment model is independent from the identification of a troubled debt restructuring.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Leases12/2/10 | Assurance services
PwC expressed support for the boards' objective to report relevant and representationally faithful information to users of financial statements about the amounts, timing and uncertainty of cash flows arising from leases. The firm acknowledges that the proposals address the primary concern - that is, the recognition of assets and liabilities arising out of lease contracts - however, application of the proposals might reduce the income statement usefulness to many users. The firm believes that the proposals will result in significant cost and complexity for some preparers. The firm does not believe that the current proposals fully meet the objective in a number of key areas including the measurement of more complex leases, specifically...
PwC comment letter (IASB)
PwC Comments on Consultation Document: The annual improvements process: Proposals to amend the Due Process Handbook for the IASB12/2/10 | Global accounting consulting services
PwC supports the proposal to amend the Due Process Handbook to include criteria for assessing whether an issue should be dealt with through the annual improvements project. PwC agrees that it is helpful to have criteria for distinguishing between potential improvements and more significant projects. In the letter, PwC provides some comments drafting suggestions.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Leases12/2/10 | Global accounting consulting services
PwC expressed support for the boards' objective to report relevant and representationally faithful information to users of financial statements about the amounts, timing and uncertainty of cash flows arising from leases. The firm acknowledges that the proposals address the primary concern - that is, the recognition of assets and liabilities arising out of lease contracts - however, application of the proposals might reduce the income statement usefulness to many users. The firm believes that the proposals will result in significant cost and complexity for some preparers. The firm does not believe that the current proposals fully meet the objective in a number of key areas including the measurement of more complex leases, specifically...
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Severe Hyperinflation: Proposed Amendment to IFRS 112/2/10 | Global accounting consulting services
PwC believes that an amendment to address severe hyperinflation should be made to IAS 29 rather than IFRS 1 because the entities that requested the board consider this issue are unable to prepare financial statements in accordance with IFRSs, as they cannot apply the measurement requirements of IAS 29. PwC is concerned that an amendment to IFRS 1 could be applied more widely than the board intends.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Insurance Contracts12/1/10 | Global accounting consulting services
PwC believes the IASB should continue to work with the FASB in evaluating and making changes responsive to comments received, resolving current differences between the Boards, and developing a global insurance standard. PwC expresses concerns about certain aspects of both the IASB and FASB proposals. One key concern is how the proposals would interact with other standards that are relevant to insurers' financial statements. PwC believes the IASB and FASB need to resolve their remaining differences on this project, address the concerns regarding the proposed models raised in PwC's letter to the IASB, and finalize one converged financial instruments standard, in order for a proposed insurance contracts accounting standard to be...
PwC comment letter (FASB)
PwC Comments on FASB Discussion Paper: Preliminary Views on Insurance Contracts11/30/10 | Assurance services
PwC believes the FASB should continue to work with the IASB in evaluating and making changes responsive to comments received, resolving current differences between the Boards, and developing a global insurance standard. PwC expresses concerns about certain aspects of both the IASB and FASB proposals. One key concern is how the proposals would interact with other standards that are relevant to insurers' financial statements. PwC believes the FASB and IASB need to resolve their remaining differences on this project, address the concerns regarding the proposed models raised in PwC's letter to the IASB, and finalize one converged financial instruments standard, in order for a proposed insurance contracts accounting standard to be...
PwC comment letter (IFAC)
PwC Comments on Proposed Revised ISA 610, Using the Work of Internal Auditors, and Related Enhancements to ISA 315 (Revised)11/30/10 | Assurance services
PwC believes that the proposed revisions will prove beneficial to external auditors in: (1) explaining how the internal audit function can inform the external auditor's understanding of the entity and risk assessment; and (2) determining if, and when, it is appropriate for the external auditor to use the work of internal audit.
PwC comment letter (IFAC)
PwC Comments on Proposed ISAE, Assurance Reports on the Process to Compile Pro Forma Financial Information Included in a Prospectus11/16/10 | Global accounting consulting services
PwC is concerned that the emphasis in the proposed standard on the "process to compile" may result in users underestimating the applicability and usefulness of the standard, and the level of assurance that the work effort actually supports. The firm suggests that certain proposals within the exposure draft, along with the title of the standard, be amended to refer to the "proper compilation" of the pro forma information.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Deferred Tax: Recovery of Underlying Assets (Proposed amendments to IAS 12)11/15/10 | Global accounting consulting services
PwC does not support the specific proposals in the exposure draft. PwC has suggested an alternative approach that addresses concerns with the current model in a way that reflects the economic consequences of recovering an asset measured at fair value but also minimizes the risk of unintended consequences.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Disclosure about an Employer's Participation in a Multiemployer Plan11/8/10 | Assurance services
PwC believes the proposed ASU would improve the transparency of disclosure and provide incremental information useful to assess the risks of an employer's participation in a multiemployer plan. PwC believes, however, that there are practical implementation issues that employers and plans will face in complying with the proposed requirements, which the firm recommends that the Board consider.
PwC comment letter (IASB)
PwC Comments on Tentative Agenda Decisions re: IAS 36 Impairment of Assets11/8/10 | Global accounting consulting services
Regarding IAS 36 calculation of value in use, PwC agrees with the decision of the IFRS IC not to take this item onto its agenda. PwC, however, encourages the IFRS IC to clarify the reasons for its conclusion so that the published rejection notice does not have unintended consequences. Regarding IAS 36 accounting for impairment testing of goodwill when non controlling interests (NCI) are recognized, PwC disagrees with the decision of the IFRS IC not to recommend this item for inclusion in Annual Improvements. PwC believes that the issue can and should be dealt with as part of the Annual Improvement projects to allow for resolution in a more timely manner than waiting for the outcome of an IFRS 3 post-implementation review. The firm...
PwC comment letter (FASB)
PwC Comments on Proposed FASB Roundtable Meeting Agenda re: IASB Staff Draft, IFRS X - Consolidated Financial Statements11/4/10 | Assurance services
PwC continues to believe that the consolidation guidance should not be reconsidered separately from a reconsideration of the derecognition guidance. PwC believes that even if the FASB adopts a consolidation model that is more consistent with the model described in the Staff Draft, convergence, and therefore consistency and comparability, will not be achieved, particularly for securitization entities, unless a converged derecognition model is also adopted. Accordingly, PwC believes that the FASB should reconsider the consolidation guidance together with the derecognition guidance.
PwC comment letter (PCAOB)
PwC Comments on Concept Release: Application of the "Failure to Supervise" Provision of the Sarbanes-Oxley Act of 200211/4/10 | Assurance services
The Concept Release requests comments on the concept of proposing rules requiring registered firms to make and document clear assignments of responsibility for implementation of Quality Control. Although supportive of the objective to clarify supervisory responsibilities, PwC does not believe separate rulemaking is necessary. Rather, the firm believes that this effort should be implemented through the quality control projects already on the Board's agenda. In addition, if the Board were to undertake separate rulemaking in this area, PwC supports a general framework of assignment and documentation rather than prescriptive rules.
PwC comment letter (AICPA)
PwC Comments on Proposed SSARS, The Applicability of Statements on Standards for Accounting and Review Services11/1/10 | Assurance services
PwC supports the proposed revision of paragraph .01 of AR 90, Review of Financial Statements, such that the SSARS would not apply to a review of interim financial information when the accountant audited the entityÆs latest annual financial statements and the appointment of an auditor to audit the current year financial statements is not effective prior to the beginning of the period covered by the review. ...
PwC comment letter (FASB)
PwC Comments on Exposure Draft: Revenue from Contracts with Customers10/25/10 | Global accounting consulting services
PwC agrees with the theoretical merit of many of the concepts included in the proposed standard. PwC believes, however, that there are a number of situations where the concepts may be difficult to apply, do not appear cost beneficial, or both. PwC also agrees with the boards that full retrospective application of the proposed standard might benefit users, but a more pragmatic approach to transition might likely be needed in many situations. The firm encourages the boards to allow for early adoption of the proposed standard.
PwC comment letter (IASB)
PwC Comments on Exposure Draft: Removal of fixed dates for first-time adopters (proposed amendments to IFRS 1)10/19/10 | Global accounting consulting services
PwC agrees with the proposed amendments in the exposure draft and believes that the removal of the references to fixed dates in the standard is consistent with the principles of IFRS 1.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Statement of Comprehensive Income9/27/10 | Assurance services
PwC recommends that the FASB and IASB develop a set of consistent principles to govern the use of other comprehensive income. PwC encourages the Boards to add to their post-2011 agendas a project to address the reporting of financial performance, the purpose and use of other comprehensive income, and the extent to which recycling is appropriate. Many companies and financial statement users continue to believe that a measure of net income is important. PwC, therefore, supports the requirement to present this sub-total within a single statement of comprehensive income and the Firm believes strongly that this line item should be retained as the Boards develop their thinking on the presentation of financial statements.
PwC comment letter (FASB)
PwC Comments on Proposed ASU: Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRS9/9/10 | Assurance services
Although PwC generally agrees with proposals that would enhance consistency between U.S. GAAP and IFRS, the Firm believes the ED should be modified in certain areas described in detail in the letter and recommends that the FASB and the International Accounting Standards Board (IASB) work together to reconcile any substantive differences and work to achieve convergence in fair value measurement and disclosure guidance.
PwC comment letter (FASB)
PwC Comments on Proposed ASU, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities9/2/10 | Assurance services
As the financial instruments area is fundamental to any convergence efforts, and the cost to the capital markets of divergence would be significant on many levels, PwC urges the FASB and IASB to work collaboratively during the redeliberations phase to resolve remaining substantive differences. PwC supports the FASB's objective of developing a model that increases the decision-usefulness of the information reported about financial instruments. However, PwC believes that the Proposal, taken as a whole, does not contain the most appropriate solutions to achieve that objective.