Recommended Reading, listed below, includes various FASB and IASB proposed standards, PCAOB Concept Releases and proposed rules, and SEC proposed rulemaking and Staff Papers currently out for public comment. Recommended Writing would include - no, not a 'book report,' but a well thought-out comment letter on any proposal(s) that could impact you as a preparer, investor, auditor, attorney, analyst, board member, or in any other capacity.
Proposals Out For Comment
If you are a regular reader of this blog, you've seen us highlight for you some of these proposals (listed below, along with the applicable comment deadline):
- PCAOB Concept Release on the Auditor's Reporting Model. Comment deadline: Sept. 30. (see also our recent post on PCAOB's proposed rulemaking for broker-dealer audits and supplemental information by all issuers.)
- SEC Staff Paper on IFRS (aka IFRS 'Condorsement' or ongoing endorsement by FASB for use in the U.S., as one possible path to incorporating IFRS into the U.S. financial reporting system). Comment deadline: July 31.
- FASB, IASB upcoming Exposure Draft on Revenue Recognition: expected to be released 3Q 2011, with a 120-day comment deadline.
- FAF Seeking Input On Private Co. Standard-Setting, as it considers recommendation of Blue Ribbon Panel; conclusions expected to be announced 3Q 2011.
- IFRS Foundation Seeks Comment on 2nd Strategy Review Document; comments due July 25.
- SEC proposed rulemaking implementing the Dodd-Frank Act , most recently, including Proposed Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants (Comment deadline: Aug. 29). See also additional proposed, final rules at that link.
Additional Reading on Audit-Related Rulemaking
There are many excellent sources of commentary and analysis ranging from 'Cliff Notes' or 'SparkNotes' versions of the above proposed rulemaking, to indepth analysis that ties historical developments and critical analysis (sometimes, very critical, or shall we say, vocal) of the proposals and the events that in some cases preciptated them.
Before I continue to reference a couple of sources of recommended reading, please note the disclaimer that appears on the right side of this blog. Additionally, please note that I personally may not agree with the opinions taken by these other writers, but I believe reading their posts can provide some important food for thought, particularly for those contemplating drafting comment letters on the related proposals.
These writers have done a fair amount of research (the first post below, by Francine McKenna, links to a plethora of related material, including speeches and analysis, in addition to her own observations) and have seen a fair amount of things in their professional careers (the second author below, Jim Peterson, served as a senior attorney and partner at Andersen) to make it worth your while to take a look at these posts, both of which relate to the first item listed above, the PCAOB's Concept Release on the auditor's reporting model. The PCAOB's Concept Release is significant in that it could be the first step toward what could potentially result in major changes to the content of the auditor's report, therein potentially changing the way audits are conducted. Or, not (depending on analysis of the proposals and practical feedback provided in the comment letter process and the upcoming public roundtable, date t/b/a). I suggest reading:
- Going in Circles, a Few Remarks on Audit Reform, in Francine McKenna's Re:TheAuditors
- The Independent Auditor's Real Client: Time to Reassess, I Kid You Not; and The PCAOB's Concept Release: What Might A Truly Useful Auditor's Report Truly Say? in Jim Peterson's Re:Balance
Some other go-to sources (which again, I may not always agree with, but provide useful reading to get up to speed on an issue, and related analysis) on proposed rulemaking such as the items listed above, in particular SEC rulemaking, include:
TheCorporateCounsel.net Blog by Broc Romanek & Dave Lynn
IR Web Report by Dominic Jones, Pam Agnew & their team
On the subject of IFRS convergence, and particular FASB, IASB proposals, voices of the 'loyal opposition' often include:
The Accounting Onion by Tom Selling, and
The Summa, by Prof. Dave Albrecht.
See also these useful blog aggregators and listservs; many voices, one platform:
Securities Mosaic Blogwatch (sub req'd)
Going Concern (not for the faint of heart)
Magazines/websites and other publications:
The Analyst's Accounting Observer, by Jack Ciesielski (sub req'd)
BNA Daily Report for Executives (the home of Steve Burkholder, Denise Lugo, and many other exceptional writers particularly on the FASB/IASB beat) (sub req'd)
Compliance Week (sub req'd)
This list of recommended reading/resources is not meant to be a complete listing, but meant to provide some alternative points of view and information to assist you in reviewing and potentially preparing comment letters on some of this summer's significant proposed rulemaking.
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