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U.S. comment letter on going concern

Published on: Sep 25, 2013

The following is an excerpt from the comment letter:

We agree that management has the responsibility for assessing an entity’s going-concern presumption when preparing financial statements. Accordingly, we believe that three key objectives should be accomplished in the going-concern project: (1) to articulate and confirm that management has the responsibility to perform the assessment, (2) to clarify the substantial-doubt threshold (not defined in current auditing literature), and (3) to require that entities provide disclosure about going-concern uncertainty even when substantial doubt is not yet and may not be present. While the proposal makes strides toward meeting these objectives, we have concerns, as discussed below, about whether certain aspects of the proposed ASU’s requirements fully accomplish these objectives.

The comment letter also discusses concerns regarding:

  • Complexity.
  • Time horizon.
  • Information assessed.
  • Coordination with PCAOB and ASB.
  • Coordination with SEC.

Full text of the comment letter is available below.


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