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APPENDIX I
SUMMARY OF
RECOMMENDATIONS
SUMMARY OF RECOMMENDATIONS
This appendix provides a concise listing of the Committee's recommendations. The rationale and basis for each recommendation are discussed in chapters 5 through 8.
IMPROVING THE TYPES OF INFORMATION IN BUSINESS REPORTING
CHAPTER 5
Recommendation 1: Standard setters should develop a comprehensive model of business reporting indicating the types and timing of information that users need to value and assess the risk of their investments.
- The model should be based on certain concepts to guide reporting
under the comprehensive model See appendix II.
- The model should include practical constraints on disclosures
to reduce costs when costs could be significant See appendix
II.
- To assess the feasibility of its ideas, the Committee designed
and illustrated a comprehensive model based on the abovenoted
concepts, its understanding of users' needs for information, and
information about costs of reporting See appendix II.
Recommendation 2: Improve understanding of costs and benefits of business reporting, recognizing that definitive quantification of costs and benefits is not possible.
- See chapter 5 for examples of the types of research to consider.
FINANCIAL STATEMENTS AND RELATED DISCLOSURES CHAPTER 6
Recommendation 1: Improve disclosure of business segment information.
- Basis of segmentation See appendix II, item I(A)7(a).
- Information to report about segments See appendix II, item
I(A)7(b).
- Restatement of historical segment information when segments
change See appendix II, item I(A)7©.
- Format of disclosures See appendix II, item I(A)7(d).
- Information related to unconsolidated entities See appendix
II, item I(A)7(e).
Recommendation 2: Address the disclosures and accounting for innovative financial instruments.
- Broader guidance that addresses fundamental issues is needed.
The guidance would provide a framework for addressing the accounting
for future innovations in financial instruments, thereby leading
rather than lagging behind the pace of change.
- The Committee's study of users' needs affirmed the critical
importance of improving disclosures and accounting for innovative
financial instruments. The FASB is addressing the appropriate
issues and it is right to give that work the highest priority.
Recommendation 3: Improve disclosures about the identity, opportunities, and risks of offbalancesheet financing arrangements and reconsider the accounting for those arrangements.
- The FASB should emphasize disclosures in its projects on unconsolidated
entities, special purpose entities, and securitizations.
- The FASB should not reconsider the accounting for leases at
this time; however, it should add a limitedscope project to its
agenda to improve disclosures by lessees of operating leases.
Recommendation 4: Report separately the effects of core and noncore activities and events, and measure at fair value noncore assets and liabilities.
- Display of core and noncore activities and events See appendix
II, item I(A)4(a): Income Statement Statement of Cash Flows
Balance Sheet
- Measurement of noncore assets and liabilities See appendix
II, item I(A)3(a).
Recommendation 5: Improve disclosures about the uncertainty of measurements of certain assets and liabilities.
- Identify in financial statement notes the specific types of
assets and liabilities subject to significant measurement uncertainties.
- For assets and liabilities subject to significant measurement
uncertainties, disclose how the reported amounts were derived
and explain the estimates, assumptions, and judgments about future
events considered in their measurement.
- The key to meaningful disclosure is to be selective about
the measurement uncertainties disclosed.
Recommendation 6: Improve quarterly reporting by reporting on the fourth quarter separately and including business segment data.
- Fourthquarter reporting should be no different from the reporting
on other quarters except for the disclosure of significant yearend
adjustments.
- Notes related to yearend balance sheet amounts can generally
be omitted if the fourthquarter financial statements are included
in annual reporting.
Recommendation 7: Standard setters should search for and eliminate less relevant disclosures.
Other recommendations
- Display of information in financial statements
- Interim reporting Interim reporting should include
quarterly cash flow statements. Interim information should include
uncondensed financial statements; however, condensed note disclosures
remain appropriate at interim periods. Companies should disclose
the methods of computing reported amounts used in interim periods
that differ from the methods used at yearend.
- Comparability and consistency of information Companies
should restate or reclassify information in more circumstances
than allowed in current practice for dispositions, accounting
changes, changes on the definitions of business segments, and
possibly other items as well if the restated or reclassified information
can be assembled reasonably and is necessary for a better and
more complete understanding of the business. Standard setters
should consider simplifying the procedure for adopting new pronouncements
by making them effective for all companies in a single year and
prescribing only one method of adoption.
- Key statistics and ratios Companies should provide
a summary of key financial and nonfinancial data on a consolidated
basis as well as for each business segment. A company and the
users of its business reporting should agree on the periods to
be reported for the summary information, which generally need
not exceed five years.
- Lower priority issues
AUDITOR ASSOCIATION WITH BUSINESS REPORTING ; CHAPTER
7
Recommendation 1: Allow for flexible auditor association with business reporting, whereby the elements of information on which auditors report and the level of auditor involvement with those elements are decided by agreement between a company and the users of its business reporting.
- The level of auditor assurance selected for the financial
statement element, if any, should determine the maximum level
of assurance that could be provided on other elements reported.
Recommendation 2: The auditing profession should prepare to be involved with all the information in the comprehensive model, so companies and users can call on it to provide assurance on any of the model's elements.
- One standard setter, the Auditing Standards Board, should
assume responsibility for new auditing standards.
- Reporting on objective information in the comprehensive model.
; To the extent possible, current auditing standards should
be retained. ; Existing standards are adequate for auditing
and reporting on information in some elements of the model but
not others. See chapter 7 for a list of those elements for which
existing standards are considered adequate.
- Reporting on subjective information in the comprehensive model.
; Existing audit guidance is not sufficient, and new standards
will be required. See chapter 7 for a list of those elements for
which existing standards are not considered adequate. ; A
different (lower) level of assurance from the level provided for
information that is verifiable objectively should be expressed
using an approach that encompasses the style of current attestation
standards as follows: Reasonable basis for presentation. Conformity
with presentation standards.
- Standardized reporting. ; Standardized reporting should
be supported. ; The historical longform report is not an
acceptable alternative to the standardized expression of an auditor's
final conclusion on the fairness of financial statements.
- The Special Committee on Assurance Services and the Auditing
Standards Board should pursue the subject of alternative levels
of assurance within the Committee's reporting framework.
Recommendation 3: The newly formed AICPA Special Committee on Assurance Services should research and formulate conclusions on analytical commentary in auditors' reports within the context of the Committee's model, focusing on users' needs for information.
Recommendation 4: The profession should continue its projects on other matters related to auditor association with business reporting.
- Those projects are reporting on internal controls, credibility
of business reporting and pressures on auditor independence, and
responsibility for detecting fraud.
FACILITATING CHANGE IN BUSINESS REPORTING ; CHAPTER 8
Recommendation 1: National and international standard setters and regulators should increase their focus on the information needs of users, and users should be encouraged to work with standard setters to increase the level of their involvement in the standardsetting process.
- Those responsible for standardsetting processes, such as the
Financial Accounting Foundation, the FASB's parent organization,
and standard setters themselves should more effectively recruit
users for service on standardsetting boards, advisory councils,
and task forces.
- Those responsible for standardsetting processes should seek
formal commitments to increase user participation from institutions
representing users, such as the Association of Investment Management
and Research and the Robert Morris Associates, or major institutional
investors and other organizations.
- Those responsible for standardsetting processes should consider
novel vehicles to get qualified users to focus exclusively on
users' needs for the benefit of the standardsetting process (for
example, focus groups and task forces made up of recently retired
users).
- Standard setters should more aggressively search for, sponsor,
and undertake research about how users make decisions and about
the relative usefulness of various types of information in their
decision making processes.
- Standard setters should become more active in helping steer
research programs into areas that are relevant to the standardsetting
process.
Recommendation 2: U.S. standard setters and regulators should continue to work with their non U.S. counterparts and international standard setters to develop international accounting standards, provided the resulting standards meet users' needs for information.
- Any approach that would sacrifice users' needs for information
to the goal of creating international standards should be rejected.
- A policy of mutual recognition should be rejected, except
when the differences among disclosure presentations are immaterial.
Recommendation 3: Lawmakers, regulators, and standard setters should develop more effective deterrents to unwarranted litigation that discourages companies from disclosing forwardlooking information.
- Legislators and regulators should create more effective safe
harbors and should adopt other measures that discourage unwarranted
litigation.
- Standard setters should reduce the threat of unwarranted litigation
by developing provisions for forwardlooking disclosures that enable
companies to demonstrate compliance.
Recommendation 4: Companies should be encouraged to experiment voluntarily with ways to improve the usefulness of reporting consistent with the Committee's model. Standard setters and regulators should consider allowing companies that experiment to substitute information specified by the model for information currently required.
Recommendation 5: Standard setters should adopt a longer term focus by developing a vision of the future business environment and users' needs for information in that environment. Standards should be consistent directionally with that longterm vision.
- Standard setters should have some systematic approach to awareness
of the likely importance of economic and technological changes
for business reporting so that agenda priorities are well chosen,
resources are effectively deployed, and standards are appropriate
to the environment in which they are to be applied.
- To ensure the perceptiveness and quality of their vision,
standard setters should consider assistance from experts in various
disciplines ; finance, accounting, economics, law, business
strategy, behavioral science, and technology, for example.
Recommendation 6: Regulators should consider whether there are any alternatives to the current requirement that public companies make all disclosures publicly available.
- The fully public disclosure requirements should not be abandoned;
however, regulators should explore whether there are any alternatives.
- Regulators should consider whether the cost of reporting sensitive
information to competitors could become an undesirable barrier
to
providing the most useful information to users and therefore to allocating capital effectively.
Recommendation 7: The AICPA should establish a Coordinating Committee charged to ensure that the recommendations in this report are given adequate consideration by those who can act on them.
- The Coordinating Committee should be responsible for the activities
listed in chapter 8.
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