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Mazars USA LLP is committed to supporting professional standards and we are pleased to present our Comment Letters and responses related to recent, proposed accounting, auditing, professional standards, and regulatory changes. Our Comment Letters are prepared by our Quality & Risk Management team.
 
Learn more about Quality & Risk Management at Mazars here.
 

Featured Comment Letters


Comment Letter – File Number S7-26-18- Request for Comment on Earnings Releases and Quarterly Reports

March 21, 2019
Mazars USA LLP (“Mazars”) welcomes the opportunity to comment on File Number S7-26-18- Request for Comment on Earnings Releases and Quarterly Reports (the “Release”).


Comment Letter – Tax Policy & Statistics Division
Centre for Tax Policy & Administration
OECD

March 6, 2019
This letter is submitted in response to the request for comment addressing the Tax Challenges of the Digitalization of the
Economy, undertaken as part of the OECD’s Base Erosion & Profit Shifting Project.

 

Other Recent Comment Letters

 
Comment Letter – PCAOB Release No. 2017-002 Rulemaking (Docket Matter No. 043) – Auditing Accounting Estimates, Including Fair Value Measurements and Proposed Amendments to PCAOB
Auditing Standards

August 30, 2017
This letter is submitted in response to the request for comment on the PCAOB Release No. 2017-002 Rulemaking (Docket Matter No. 043) – Auditing Accounting Estimates, Including Fair Value Measurements and Proposed Amendments to PCAOB Auditing Standards.

Comment Letter – PCAOB Release No. 2017-003 Rulemaking (Docket Matter No. 044) – Proposed Amendments to Auditing Standards for Auditor’s Use of the Work of Specialists

August 30, 2017
This letter is submitted in response to the request for comment on the PCAOB Release No. 2017-003 Rulemaking (Docket Matter No. 044) – Proposed Amendments to Auditing Standards for Auditor’s Use of the Work of Specialists.
Comment Letter – PCAOB Release No. 2015-005 (Docket Matter No. 41) – Concept Release on Audit Quality Indicators
October 22, 2015
This letter is submitted in response to the request for comment on the PCAOB Release No. 2015-005 (Docket Matter No. 41) – Concept Release on Audit Quality Indicators.

Comment Letter – Release No. 33-9862 File No. S7-13-15 Possible Revisions to Audit Committee Disclosures (“Concept Release Paper”)

September 23, 2015
This letter is submitted in response to the request for comment on the Securities and Exchange Commission’s Concept Release Paper No. 33-9862 File No. S7-13-15.

Comment Letter – PCAOB Release No. 2015-004 Supplemental Request for Comment: Rules to Require Disclosure of Certain Audit Participants on a new PCAOB Form
September 9, 2015
This letter is submitted in response to the request for comment on the Rules to Require Disclosure of Certain Audit Participants on a new PCAOB Form.

Comment Letter – Proposed Accounting Standards Update, Not-for-Profit Entities (Topic 958) and Health Care Entities (Topic 954), Presentation of Financial Statements of Not-for-Profit Entities
August 20, 2015
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board (FASB) with respect to its Exposure Draft of the Proposed Accounting Standards Update (ASU), Not-for-Profit Entities (Topic 958) and Health Care Entities (Topic 954) Presentation of Financial Statements of Not-for-Profit Entities.

Comment Letter – PCAOB Staff Consultation Paper No. 2015-01: The Auditor’s Use of the Work of Specialists (“Staff Consultation Paper”)
July 30, 2015
This letter is submitted in response to the request for comment on the Staff Consultation Paper No. 2015-01: The Auditor’s Use of the Work of Specialists.

Comment Letter – File Reference No. 2014-270: Proposed Accounting Standards Update – Financial Services—Investment Companies (Topic 946), Disclosures about Investments in Other Investment Companies.
February 17, 2015
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board (FASB) with respect to its Exposure Draft of the Proposed Accounting Standards Update (ASU) Financial Services—Investment Companies (Topic 946), Disclosures about Investments in Other Investment Companies.

Comment Letter – Reference No. EITF-14B: Proposed Accounting Standards Update, Fair Value Measurement (Topic 820), Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent), a consensus of the FASB Emerging Issues Task Force
January 15, 2015
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update (ASU), Fair Value Measurement (topic 820), Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent), a consensus of the FASB Emerging Issues Task Force. Mazars USA LLP appreciates the opportunity to review and comment on this Exposure Draft.


Comment Letter – File Reference No. 2014-230: Proposed Accounting Standards Update, Intangibles – Goodwill and Other – Internal Use Software (Subtopic 350-40) Customer’s Accounting for Fees Paid in a Cloud Arrangement
November 18, 2014 by Mazars USA LLP
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update, Intangibles-Goodwill and Other—Internal Use Software (Subtopic 350-40) Customer’s Accounting for Fees Paid in a Cloud Computing Arrangement


Comment Letter – AICPA Discussion Paper – Enhancing Audit Quality, Plans and Perspectives for the U.S. CPA Profession
November 03, 2014 by Mazars USA LLP
This letter is submitted in response to the request for AICPA Discussion Paper – Enhancing Audit Quality, Plans and Perspectives for the U.S. CPA Profession.

Comment Letter – PCAOB Staff Consultation Paper, Auditing Accounting Estimates and Fair Value Measurements (“Staff Consultation Paper”)
November 03, 2014 by Mazars USA LLP
This letter is submitted in response to the request for PCAOB Staff Consultation Paper, Auditing Accounting Estimates and Fair Value Measurements (“Staff Consultation Paper”).

Comment Letter – File Reference No. 2014-210: Proposed Accounting Standards Update, Inventory (Topic 330), Simplifying the Measurement of Inventory
September 30, 2014 by Mazars USA LLP
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update, Inventory(Topic 330), Simplifying the Measurement of Inventory.

Comment Letter – File Reference No. 2014-220: Proposed Accounting Standards Update, Income Statement—Extraordinary and Unusual Items (Subtopic 225-20), Simplifying Income Statement Presentation by Eliminating the Concept of Extraordinary Items
September 30, 2014 by Mazars USA LLP
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update, Income Statement – Extraordinary and Unusual Items (Subtopic 225-20), Simplifying Income Statement Presentation by Eliminating the Concept of Extraordinary Items.

Comment Letter – PCAOB Release No. 2013-009, Rulemaking Docket Matter No. 029
March 13, 2014 by Mazars USA LLP
Here you will find our response to PCAOB Release No. 2013-009, Rulemaking Docket Matter No. 029 on Improving the Transparency of Audits: Proposed Amendments to PCAOB Standards to Provide Disclosure in the Auditor’s Report of Certain Participants in the Audit.

Comment Letter – PCAOB Release No. 2013-005, Rulemaking Docket Matter No. 034
March 11, 2014 by Mazars USA LLP
Here you will find our response to PCAOB Release No. 2013-005, Rulemaking Docket Matter No. 034 on Proposed Auditing Standards for Financial Statements.


Comment Letter – IASB 2nd Exposure Draft and the FASB Proposed Accounting Standard Update: Leases (2013-270, No. 641)
January 14, 2014 by Mazars and Mazars
Mazars and Mazars’ welcome the opportunity to comment on the IASB 2nd Exposure Draft Leases and the FASB Proposed Accounting Standard Update (Revised) Leases


Comment Letter – FASB Topic 815 (File Reference No. EITF-13G)
December 20, 2013 by Mazars USA LLP
Here you will find our response to the Proposed Accounting Standards Update on Derivatives and Hedging (Topic 815) Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share Is More Akin to Debt or to Equity, a consensus of the FASB Emerging Issues Task Force.


Comment Letter – FASB Topic 718 (File Reference No. EITF-13D)
December 20, 2013 by Mazars USA LLP
Attached is our response to the Proposed Accounting Standards Update on Stock Compensation (Topic 718) Accounting for Share-Based Payments When the Terms of an Award Provide That a Performance Target Could Be Achieved after the Requisite Services Period, a consensus of the FASB Emerging Issues Task Force.


Comment Letter – PCAOB Rulemaking Docket Matter No. 40
June 26, 2013 by Mazars USA LLP
Attached is our response to the Proposed Framework for Reorganization of PCAOB Auditing Standards and Related Amendments to PCAOB Auditing Standards and Rules.


Comment Letter – FASB Topic 350 (2012-100, No. 23)
April 24, 2012 by Mazars USA LLP
Mazars is pleased to comment on the Proposed Accounting Standards Update on Intangibles – Goodwill and Other (Topic 350), Testing Indefinite-Lived Intangible Assets for Impairment.


Comment Letter – FASB Topic 605
March 13, 2012 by Mazars USA LLP
Attached is our response to FASB’s Proposed Accounting Standards Update: Revenue Recognition (Topic 605), Revenue from Contracts with Customers.

Comment Letter – FASB Topic 973
February 16, 2012 by Mazars USA LLP
Attached is our response to FASB’s Proposed Accounting Standards Update: Real Estate – Investment Property Entities (Topic 973).

Comment Letter – FASB Topic 946
February 16, 2012 by Mazars USA LLP
Here you will find our response to FASB’s Proposed Accounting Standards Update: Financial Services – Investment Companies (Topic 946), Amendments to the Scope, Measurement, and Disclosure Requirements.

 

 

     
 

 
     

 

   
 
 

 

 

COMMENT LETTERS

Mazars USA LLP is committed to supporting professional standards and we are pleased to present our Comment Letters and responses related to recent, proposed accounting, auditing, professional standards, and regulatory changes. Our Comment Letters are prepared by our Quality & Risk Management team.

Learn more about Quality & Risk Management at Mazars here.

Featured Comment Letter

Comment Letter – PCAOB Release No. 2017-002 Rulemaking (Docket Matter No. 043) – Auditing Accounting Estimates, Including Fair Value Measurements and Proposed Amendments to PCAOB
Auditing Standards

August 30, 2017
This letter is submitted in response to the request for comment on the PCAOB Release No. 2017-002 Rulemaking (Docket Matter No. 043) – Auditing Accounting Estimates, Including Fair Value Measurements and Proposed Amendments to PCAOB Auditing Standards.

Comment Letter – PCAOB Release No. 2017-003 Rulemaking (Docket Matter No. 044) – Proposed Amendments to Auditing Standards for Auditor’s Use of the Work of Specialists

August 30, 2017
This letter is submitted in response to the request for comment on the PCAOB Release No. 2017-003 Rulemaking (Docket Matter No. 044) – Proposed Amendments to Auditing Standards for Auditor’s Use of the Work of Specialists.

Other Recent Comment Letters

Comment Letter – PCAOB Release No. 2015-005 (Docket Matter No. 41) – Concept Release on Audit Quality Indicators
October 22, 2015
This letter is submitted in response to the request for comment on the PCAOB Release No. 2015-005 (Docket Matter No. 41) – Concept Release on Audit Quality Indicators.

Comment Letter – Release No. 33-9862 File No. S7-13-15 Possible Revisions to Audit Committee Disclosures (“Concept Release Paper”)

September 23, 2015
This letter is submitted in response to the request for comment on the Securities and Exchange Commission’s Concept Release Paper No. 33-9862 File No. S7-13-15.

Comment Letter – PCAOB Release No. 2015-004 Supplemental Request for Comment: Rules to Require Disclosure of Certain Audit Participants on a new PCAOB Form
September 9, 2015
This letter is submitted in response to the request for comment on the Rules to Require Disclosure of Certain Audit Participants on a new PCAOB Form.

Comment Letter – Proposed Accounting Standards Update, Not-for-Profit Entities (Topic 958) and Health Care Entities (Topic 954), Presentation of Financial Statements of Not-for-Profit Entities
August 20, 2015
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board (FASB) with respect to its Exposure Draft of the Proposed Accounting Standards Update (ASU), Not-for-Profit Entities (Topic 958) and Health Care Entities (Topic 954) Presentation of Financial Statements of Not-for-Profit Entities.

Comment Letter – PCAOB Staff Consultation Paper No. 2015-01: The Auditor’s Use of the Work of Specialists (“Staff Consultation Paper”)
July 30, 2015
This letter is submitted in response to the request for comment on the Staff Consultation Paper No. 2015-01: The Auditor’s Use of the Work of Specialists.

Comment Letter – File Reference No. 2014-270: Proposed Accounting Standards Update – Financial Services—Investment Companies (Topic 946), Disclosures about Investments in Other Investment Companies.
February 17, 2015
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board (FASB) with respect to its Exposure Draft of the Proposed Accounting Standards Update (ASU) Financial Services—Investment Companies (Topic 946), Disclosures about Investments in Other Investment Companies.

Comment Letter – Reference No. EITF-14B: Proposed Accounting Standards Update, Fair Value Measurement (Topic 820), Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent), a consensus of the FASB Emerging Issues Task Force
January 15, 2015
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update (ASU), Fair Value Measurement (topic 820), Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent), a consensus of the FASB Emerging Issues Task Force. Mazars USA LLP appreciates the opportunity to review and comment on this Exposure Draft.


Comment Letter – File Reference No. 2014-230: Proposed Accounting Standards Update, Intangibles – Goodwill and Other – Internal Use Software (Subtopic 350-40) Customer’s Accounting for Fees Paid in a Cloud Arrangement
November 18, 2014 by Mazars USA LLP
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update, Intangibles-Goodwill and Other—Internal Use Software (Subtopic 350-40) Customer’s Accounting for Fees Paid in a Cloud Computing Arrangement


Comment Letter – AICPA Discussion Paper – Enhancing Audit Quality, Plans and Perspectives for the U.S. CPA Profession
November 03, 2014 by Mazars USA LLP
This letter is submitted in response to the request for AICPA Discussion Paper – Enhancing Audit Quality, Plans and Perspectives for the U.S. CPA Profession.

Comment Letter – PCAOB Staff Consultation Paper, Auditing Accounting Estimates and Fair Value Measurements (“Staff Consultation Paper”)
November 03, 2014 by Mazars USA LLP
This letter is submitted in response to the request for PCAOB Staff Consultation Paper, Auditing Accounting Estimates and Fair Value Measurements (“Staff Consultation Paper”).

Comment Letter – File Reference No. 2014-210: Proposed Accounting Standards Update, Inventory (Topic 330), Simplifying the Measurement of Inventory
September 30, 2014 by Mazars USA LLP
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update, Inventory(Topic 330), Simplifying the Measurement of Inventory.

Comment Letter – File Reference No. 2014-220: Proposed Accounting Standards Update, Income Statement—Extraordinary and Unusual Items (Subtopic 225-20), Simplifying Income Statement Presentation by Eliminating the Concept of Extraordinary Items
September 30, 2014 by Mazars USA LLP
This letter is submitted in response to the request for public comment by the Financial Accounting Standards Board with respect to its Exposure Draft of the proposed Accounting Standards Update, Income Statement – Extraordinary and Unusual Items (Subtopic 225-20), Simplifying Income Statement Presentation by Eliminating the Concept of Extraordinary Items.

Comment Letter – PCAOB Release No. 2013-009, Rulemaking Docket Matter No. 029
March 13, 2014 by Mazars USA LLP
Here you will find our response to PCAOB Release No. 2013-009, Rulemaking Docket Matter No. 029 on Improving the Transparency of Audits: Proposed Amendments to PCAOB Standards to Provide Disclosure in the Auditor’s Report of Certain Participants in the Audit.

Comment Letter – PCAOB Release No. 2013-005, Rulemaking Docket Matter No. 034
March 11, 2014 by Mazars USA LLP
Here you will find our response to PCAOB Release No. 2013-005, Rulemaking Docket Matter No. 034 on Proposed Auditing Standards for Financial Statements.


Comment Letter – IASB 2nd Exposure Draft and the FASB Proposed Accounting Standard Update: Leases (2013-270, No. 641)
January 14, 2014 by Mazars and Mazars
Mazars and Mazars’ welcome the opportunity to comment on the IASB 2nd Exposure Draft Leases and the FASB Proposed Accounting Standard Update (Revised) Leases


Comment Letter – FASB Topic 815 (File Reference No. EITF-13G)
December 20, 2013 by Mazars USA LLP
Here you will find our response to the Proposed Accounting Standards Update on Derivatives and Hedging (Topic 815) Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share Is More Akin to Debt or to Equity, a consensus of the FASB Emerging Issues Task Force.


Comment Letter – FASB Topic 718 (File Reference No. EITF-13D)
December 20, 2013 by Mazars USA LLP
Attached is our response to the Proposed Accounting Standards Update on Stock Compensation (Topic 718) Accounting for Share-Based Payments When the Terms of an Award Provide That a Performance Target Could Be Achieved after the Requisite Services Period, a consensus of the FASB Emerging Issues Task Force.


Comment Letter – PCAOB Rulemaking Docket Matter No. 40
June 26, 2013 by Mazars USA LLP
Attached is our response to the Proposed Framework for Reorganization of PCAOB Auditing Standards and Related Amendments to PCAOB Auditing Standards and Rules.


Comment Letter – FASB Topic 350 (2012-100, No. 23)
April 24, 2012 by Mazars USA LLP
Mazars is pleased to comment on the Proposed Accounting Standards Update on Intangibles – Goodwill and Other (Topic 350), Testing Indefinite-Lived Intangible Assets for Impairment.


Comment Letter – FASB Topic 605
March 13, 2012 by Mazars USA LLP
Attached is our response to FASB’s Proposed Accounting Standards Update: Revenue Recognition (Topic 605), Revenue from Contracts with Customers.

Comment Letter – FASB Topic 973
February 16, 2012 by Mazars USA LLP
Attached is our response to FASB’s Proposed Accounting Standards Update: Real Estate – Investment Property Entities (Topic 973).

Comment Letter – FASB Topic 946
February 16, 2012 by Mazars USA LLP
Here you will find our response to FASB’s Proposed Accounting Standards Update: Financial Services – Investment Companies (Topic 946), Amendments to the Scope, Measurement, and Disclosure Requirements.