1. We believe it is important that the examples in ASC 958-605-55-70U through ASC 958-605- 55-70W include both intangible assets (e.g., software, intellectual property) and contributed services to make it clear that these are within the scope of the proposed disclosure amendments. For example, although the Master Glossary definition of “nonfinancial asset” includes services, we believe that many preparers do not equate services with assets and may not recognize that contributed services are also included in the scope of the disclosure requirements for the proposed amendments.

2. We believe the proposed requirement to disclose management’s intent to monetize or utilize contributed nonfinancial assets in ASC 958-605-50-1A will be difficult and costly to audit and recommend that this requirement be changed to instead required disclosure of the NFP’s board-approved policy for monetizing each category of contributed nonfinancial assets.

3. We believe the penultimate sentence in paragraph 12 in the Basis for Conclusions is misleading in its discussion of the rationale for requiring separate line item presentation of contributed nonfinancial assets on the statement of activities. This paragraph references Concepts Statement 8 (PR49), which states that “combining items measured differently into a single line item produces information that either is less meaningful or is more difficult to use.” Contributed financial assets, such as stock, and nonfinancial assets are initially measured at fair value as defined in ASC 820. Therefore, we do not believe there is a difference in how these assets are measured and recommend striking that sentence.