CUNA Regulatory Comment Call


July 13, 2006

Private Company Financial Reporting

EXECUTIVE SUMMARY

BACKGROUND

DESCRIPTION OF THE INVITATION TO COMMENT

Modifications to FASB’s Standard-Setting Process

New Committee to Promote Private Company Input into the Standard-Setting Process

QUESTIONS REGARDING THE INVITATION TO COMMENT

  1. Do you believe the proposed modifications to FASB’s standard-setting process (contained in paragraphs 16-29) will improve the accounting standard-setting process for private companies?

    Yes ______ No ______

    If yes, in what ways do you feel the proposed changes would improve the standard-setting process for private companies? If no, why not? What other/additional changes would you recommend that might be more effective in improving the standard-setting process?
















  2. Do you believe that the proposed changes to FASB’s standard-setting process will help ensure that the financial reporting needs of private companies are met?

    Yes ______ No ______

    Please explain.
















  3. The FASB and the AICPA believe that any differences in GAAP for private companies should be based on financial statement user needs and cost-benefit considerations. Do you agree?

    Yes ______ No ______

    Please explain.
















  4. The FASB and the AICPA believe that members of the new committee under consideration (except the chair) should not be compensated beyond a reasonable reimbursement of expenses. Do you agree?

    Yes ______ No ______

    If no, why do you think the new committee members should be compensated?
















  5. The FASB and the AICPA believe the committee should set its own agenda and priorities. Do you agree?

    Yes ______ No ______

    Please explain.
















  6. Other comments?
















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