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U.S. comment letter on PCC review

Published on: May 11, 2015

Deloitte & Touche LLP comments on the FAF's Three Year Review of the Private Company Council (PCC). Issued by the FAF board of trustees in February 2015, the request for feedback solicited stakeholders’ views on (1) whether the PCC is accomplishing its objectives and (2) potential improvements to the PCC.

An excerpt from the comment letter is shown below:

[W]e have generally been supportive of the PCC and the private-company decision-making framework. . . . However, we remain concerned about the potential for unnecessary divergence between public and private companies, particularly with respect to recognition and measurement, since such divergence creates unwarranted complexity. . . . Looking to the future, we are unaware of other topics in U.S. GAAP, particularly with respect to recognition and measurement, for which the needs of users of private-company financial statements differ from those of users of [public business entity] financial statements. Thus, we agree that a shift in the PCC’s focus from “look-back” projects to serving the FASB in an advisory capacity is appropriate. We believe that the PCC can play a positive role in standard setting by (1) continuing to identify accounting topics that potentially involve unnecessary complexity and (2) advising the FASB on aspects of financial reporting unique to private companies, thus promoting consideration of the needs of private companies and their financial statement users.

Full text of the comment letter is available below.


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