Financial Reporting Advisors, LLC 100 North LaSalle Street, Suite 2215 Chicago, Illinois 60602 312.345.9101 www.FinRA.com September 20, 2010 VIA EMAIL TO: Technical Director File Reference No. 1840-100 Financial Accounting Standards Board 401 Merritt 7 Norwalk, CT Re: Proposed Accounting Standards Update, Disclosure of Certain Loss Contingencies To Whom It May Concern: Our firm, Financial Reporting Advisors, LLC, provides accounting and SEC reporting advisory services, litigation support services, and dispute resolution services. We specialize in applying generally accepted accounting principles to complex business transactions. We appreciate the opportunity to provide comments on the FASB’s Proposed Accounting Standards Update, Contingencies (Topic 450): Disclosures of Certain Loss Contingencies (the Proposed Standard). Summary We highly commend the FASB for listening to its constituencies and responding to the concerns and questions arising from the Board’s 2008 proposal on disclosures of loss contingencies. We acknowledge the challenge the FASB faces in balancing the needs expressed by users for more timely and robust information on significant loss contingencies against the concerns expressed by preparers and their legal advisers regarding the disclosure of prejudicial information. Although we have a keen interest in the concerns raised by the various constituencies, because we are not principally users or preparers of financial statements, we believe our comments are most appropriately focused on issues that may affect the operationality of the Proposed Standard. Our comments respond to Question 1, the proposed disclosures operational?” Our primary “Are focus is on two areas: 1. Application of the proposed disclosure requirements to environmental-related loss contingencies 2. Implementation of the proposed requirement to disclose certain remote loss contingencies
Financial Reporting Advisors, LLC 100 North LaSalle Street, Suite 2215 Chicago, Illinois 60602 312.345.9101 www.FinRA.com September 20, 2010 VIA EMAIL TO: Technical Director File Reference No. 1840-100 Financial Accounting Standards Board 401 Merritt 7 Norwalk, CT Re: Proposed Accounting Standards Update, Disclosure of Certain Loss Contingencies To Whom It May Concern: Our firm, Financial Reporting Advisors, LLC, provides accounting and SEC reporting advisory services, litigation support services, and dispute resolution services. We specialize in applying generally accepted accounting principles to complex business transactions. We appreciate the opportunity to provide comments on the FASB’s Proposed Accounting Standards Update, Contingencies (Topic 450): Disclosures of Certain Loss Contingencies (the Proposed Standard). Summary We highly commend the FASB for listening to its constituencies and responding to the concerns and questions arising from the Board’s 2008 proposal on disclosures of loss contingencies. We acknowledge the challenge the FASB faces in balancing the needs expressed by users for more timely and robust information on significant loss contingencies against the concerns expressed by preparers and their legal advisers regarding the disclosure of prejudicial information. Although we have a keen interest in the concerns raised by the various constituencies, because we are not principally users or preparers of financial statements, we believe our comments are most appropriately focused on issues that may affect the operationality of the Proposed Standard. Our comments respond to Question 1, “Are the proposed disclosures operational?” Our primary focus is on two areas: 1. Application of the proposed disclosure requirements to environmental-related loss contingencies 2. Implementation of the proposed requirement to disclose certain remote loss contingencies
Response%20re%20Disclosure%20of%20Loss%20Contingencies%20Ref%201840-100%20(9-20-10).docx