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Deloitte comments on FASB's proposed concepts statement on presentation

Published on: Nov 09, 2016

Deloitte & Touche LLP comments on the FASB's proposed Statement of Financial Accounting Concepts Concepts Statement 8 — Conceptual Framework for Financial Reporting — Chapter 7: Presentation, which was issued in August 2016.

An excerpt from the comment letter is shown below:

We fully support the Board’s efforts to continue to develop and improve the conceptual framework, which serves as an important tool for the FASB to use now and in the future to set standards and maintain consistency among them. As we have noted in the past, the framework should be viewed as a living document and continually updated as the financial reporting environment evolves.

Presentation is and should be a critical component of the framework. The concepts regarding presentation help the Board organize financial information in a logical manner that enhances its usefulness.

Much of the proposed chapter is taken from Concepts Statement 5 — Recognition and Measurement in Financial Statements of Business Enterprises, with some added concepts. We do not disagree with the concepts carried over from Concepts Statement 5 or with those added to the proposed chapter, which encompasses many of the considerations we would expect the Board to take into account when it is developing line items in financial statements. We also recognize that the proposed chapter does not cover unit-of-account issues (e.g., separating or combining contracts). We believe that unit-of-account concepts should be addressed separately within the conceptual framework.  

However, we wish the Board had taken this opportunity to expand its discussion of certain of the concepts in the proposed chapter and to explore other concepts that are important to presentation. We touch on these items below. We hope that the Board will consider these issues when it is finalizing the proposed chapter or working on future projects involving the continual improvement of the conceptual framework.

For more information, see the full text of the comment letter which is available below.


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