CUNA Regulatory Comment Call

March 12, 2007

Valuation Guidance for Financial Reporting

EXECUTIVE SUMMARY

DISCUSSION OF THE INVITATION TO COMMENT

Need for Valuation Guidance

Level of Participation By Existing Appraisal Organizations

Process for Issuing Valuation Guidance

International Convergence

QUESTIONS CONCERNING THE REQUEST FOR COMMENTS

FASB specifically requests feedback on the questions below.

  1. Is there a need for valuation guidance specifically for financial reporting?

    If no, please explain why not. Then please skip to question 4.




    If yes, why do you believe such guidance is necessary (how would such guidance be useful)?



















  2. How specific should the additional valuation be? Should valuation guidance include conceptual valuation guidance, detailed implementation valuation guidance, or some combination of both?



















  3. What should be the duration of any valuation-guidance-setting activities?




    Please explain if you prefer a limited duration or the establishment of a permanent process and why.



















  4. What level of participation should existing appraisal organizations (preparers, auditors, regulators and investors) have in establishing valuation guidance for financial reporting? Should they have a unique role (such as an advisory role to FASB) or act as the principal standard-setter?



















  5. What process should be used for issuing valuation guidance for financial reporting? Do you favor any of the four potential processes (mentioned above) that could be used to issue valuation guidance mentioned above? Or do you have another process to recommend?



















  6. Should the process of valuation guidance be on an international or national level?
















  7. Who should grant authority to issue the valuation guidance?



















  8. What due process procedures should the standard-setter following in issuing valuation guidance?



















  9. How should any other organization that issues valuation guidance be funded?



















  10. Other comments?



















    1. Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
      Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
      Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
      Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
      Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com