Exposure Drafts, Comment Letters, and Statements of Position

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  Comment letters on proposed Statement on Auditing Standards, Auditing Financial Instruments

  American Institute of Certified Public Accountants. Auditing Standards Board

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  Proposed statement on auditing standards : amendments to Statement on auditing standards no. 61, Communication with audit committees and Statement on auditing standards no. 71, Interim financial information;Amendments to Statement on auditing standards no. 61, Communication with audit committees and Statement on auditing standards no. 71, Interim financial information; Exposure draft (American Institute of Certified Public Accountants), 1999, Oct. 1

  American Institute of Certified Public Accountants. Auditing Standards Board

  On September 28, 1998, Securities and Exchange Commission (SEC) Chairman Arthur Levitt, Jr., expressed significant concern about the quality of financial reporting in corporate America. Chairman Levitt described the problem as one that must be addressed by the entire financial community rather than the government alone and called for several actions, including the formation of a blue ribbon panel to develop recommendations to improve audit committee performance. The panel was formed and named the Blue Ribbon Committee on Improving the Effectiveness of Corporate Audit Committees (BRC). In February 1999, the BRC issued Report and Recommendations of the Blue Ribbon Committee on Improving the Effectiveness of Corporate Audit Committees. The report includes ten recommendations for strengthening the independence of the audit committee and making it more effective. Two of the recommendations (numbers 8 and 10) suggest changes to generally accepted auditing standards (GAAS). As a result of the BRC's recommendations, and in conjunction with actions expected to be taken by the New York Stock Exchange, the National Association of Security Dealers, and the SEC, in a collaborative effort to improve audit committee effectiveness, the ASB believes that the proposed amendments to Statement on Auditing Standards (SAS) No. 61, Communication With Audit Committees (AICPA, Professional Standards, vol. 1, AU sec. 380), and SAS No. 71, Interim Financial Information (AICPA, Professional Standards, vol. 1, AU sec. 722), are responsive to the BRC's recommended changes to GAAS. The ASB supports increasing the dialogue on the matters noted in the amendments to SAS Nos. 61 and 71. However, the effectiveness of this proposal is dependent on the willingness of all parties to engage in the discussion and act on the implications. This document responds to only those recommendations that suggest changes to GAAS. The ASB encourages practitioners to read the BRC's report and recommendations in its entirety. Copies are available online at www.nyse.com and www.nasd.com.

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  Proposed statement on auditing standards : amendment to statement on auditing standards no. 69, The Meaning of "Present fairly in conformity with generally accepted accounting principles" in the independent auditor's report;Amendment to statement on auditing standards no. 69, The Meaning of "Present fairly in conformity with generally accepted accounting principles" in the independent auditor's report;Meaning of "Present fairly in conformity with generally accepted accounting principles" in the independent auditor's report; Exposure draft (American Institute of Certified Public Accountants), 1999, Nov. 29

  American Institute of Certified Public Accountants. Auditing Standards Board

  The Federal Accounting Standards Advisory Board (FASAB) was organized in 1991 by the United States Department of the Treasury, the United States Office of Management and Budget, and the United States General Accounting Office to establish financial accounting and reporting standards for federal governmental entities. On October 19, 1999, AICPA Council adopted a resolution recognizing the FASAB as the body designated to establish generally accepted accounting principles (GAAP) for federal governmental entities under Rule 203, "Accounting Principles," of the AlCPA's Code of Professional Conduct. Members may now express an opinion that the financial statements of a federal governmental entity are in conformity with GAAP if they are prepared in conformity with accounting principles promulgated by the FASAB. Pursuant to the resolution, Statements of Federal Financial Accounting Standards issued by the FASAB since March 1993 are recognized as GAAP for the applicable federal governmental entities. AICPA Council's action came after an evaluation of the FASAB structure and processes based on Council-approved criteria used to assess standards-setting bodies designated to establish accounting principles under rule 203. As resolved, the AlCPA's Board of Directors will, within five years of adoption of the resolution, review the mission and operations of the FASAB and evaluate whether the FASAB continues to meet the aforementioned Council-approved criteria for standards-setting bodies. In response to the Council resolution, the AICPA Auditing Standards Board approved this exposure draft of a proposed Statement on Auditing Standards (SAS). The proposed SAS would amend SAS No. 69, The Meaning of Present Fairly in Conformity With Generally Accepted Accounting Principles in the Independent Auditor's Report (AICPA, Professional Standards, vol. 1, AU sec. 411) to reflect FASAB pronouncements in the GAAP hierarchy as sources of established accounting principles. SAS No. 69 explains the meaning of the phrase "present fairly...in conformity with generally accepted accounting principles" in the independent auditor's report. Specifically, SAS No. 69 defines sources of established accounting principles that are generally accepted in the United States. Four categories of such sources, commonly known as the GAAP hierarchy, are defined in the SAS. The proposed amendment to SAS No. 69 reflects FASAB pronouncements in the GAAP hierarchy as sources of established accounting principles, in effect defining a GAAP hierarchy for federal governmental entities. This statement amends SAS No. 69, The Meaning of Present Fairly in Conformity With Generally Accepted Accounting Principles in the Independent Auditor's Report (AICPA, Professional Standards, vol. 1, AU sec. 411).

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  Proposed statement on auditing standards : audit adjustments, reporting on consistency, and service organizations (Omnibus statement on auditing standards, 1999);Audit adjustments, reporting on consistency, and service organizations (Omnibus statement on auditing standards, 1999); Exposure draft (American Institute of Certified Public Accountants), 1999, Apr. 22

  American Institute of Certified Public Accountants. Auditing Standards Board

  This proposed Statement on Auditing Standards (SAS) amends various SASs and consists of the following three parts: Part 1, Audit Adjustments; Part 2, Reporting on Consistency; and Part 3, Service Organizations. Part 1 AUDIT ADJUSTMENTS: The amendments in part 1 of this proposed SAS are being issued to establish audit requirements that would encourage audit clients to record financial statement adjustments proposed by auditors in audits of financial statements. The Auditing Standards Board (ASB) believes such requirements would improve the financial statement reporting process. Part 1 of this proposed SAS would amend three SASs to establish audit requirements that clarify management's responsibility for the disposition of financial statement misstatements brought to its attention. The amendments would: 1. Add an item to the list of matters in AU section 310.06 that generally are addressed in the understanding with the client (the engagement letter) (see SAS No. 1, Codification of Auditing Standards and Procedures, as amended by SAS No. 83, Establishing an Understanding With the Client, AICPA, Professional Standards, vol. 1, AU sec. 310, "Appointment of the Independent Auditor"). It would indicate that management is responsible for adjusting the financial statements to correct material misstatements and for affirming to the auditor in the representation letter that the effects of any uncorrected misstatements brought to its attention by the auditor are not material, both individually and in the aggregate, to the financial statements taken as a whole. 2. Require the auditor to obtain, in the management representation letter, management's acknowledgement that it has considered the financial statement misstatements brought to its attention by the auditor and has concluded that any uncorrected misstatements are not material, both individually and in the aggregate, to the financial statements taken as a whole. It also would require that a summary of the uncorrected misstatements be included in the representation letter or in an attachment thereto. 3. Require the auditor to inform the audit committee, as defined in SAS No. 61, Communication With Audit Committees (AICPA, Professional Standards, vol. 1, AU sec. 380), about uncorrected misstatements brought to management's attention by the auditor that were determined by management to be immaterial, both individually and in the aggregate, to the financial statements taken as a whole. The amendments in part 1 of this proposed SAS would amend: 1. SAS No. 1 as amended by SAS No. 83 (AU sec. 310); 2. SAS No. 85, Management Representations (AICPA, Professional Standards, vol. 1, AU sec. 333); 3. SAS No. 61. Part 2 REPORTING ON CONSISTENCY: The amendments in part 2 of this proposed SAS are being issued to clarify which changes in the reporting entity require a consistency explanatory paragraph in the auditor's report. Part 2 of this proposed SAS amends SAS No. 1, Codification of Auditing Standards and Procedures (AICPA, Professional Standards, vol. 1, AU sec. 420, "Consistency of Application of Generally Accepted Accounting Principles"), to: 1. Conform the list of changes in AU sec. 420.07 that constitute a change in the reporting entity to the guidance in paragraph 12 of Accounting Principles Board Opinion No. 20, Accounting Changes. 2. Clarify that the auditor need not add a consistency explanatory paragraph to the auditor's report when a change in the reporting entity results from a transaction or event. 3. Eliminate the requirement to add a consistency explanatory paragraph to the auditor's report when a pooling of interests is not accounted for retroactively in comparative financial statements. (However, in these circumstances the auditor would still be required to express a qualified or adverse opinion because of the departure from generally accepted accounting principles.) 4. Eliminate the requirement to qualify the auditor's report and consider adding a consistency explanatory paragraph to the report if single year financial statements that report a pooling of interests do not disclose combined information for the prior year. The amendments in part 2 of this proposed SAS would amend SAS No. 1, AU section 420. Part 3 SERVICE ORGANIZATIONS: The amendments in part 3 of this proposed SAS are being issued to help auditors determine the kind of information about a service organization they need when auditing the financial statements of an entity that uses a service organization to process transactions. Part 3 of this proposed SAS amends SAS No. 70, Reports on the Processing of Transactions by Service Organizations (AICPA, Professional Standards, vol. 1, AU sec. 324) to: 1. Clarify the applicability of SAS No. 70 by replacing existing language with the language and concepts in SAS No. 55, Consideration of Internal Control in a Financial Statement Audit, as amended by SAS No. 78 (AICPA, Professional Standards, vol. 1, AU sec. 319), to state that the SAS is applicable when an entity obtains services from another organization that are part of the entity's "information system." 2. Provide guidance to help auditors determine whether services are part of the information system. 3. Revise and clarify the factors a user auditor should 806 consider in determining the significance of a service organization's controls to a user organization's controls. 4. Clarify the guidance on determining whether information about a service organization's controls is necessary to plan the audit. 5. Clarify that information about a service organization's controls may be obtained from a variety of sources. 6. Change the title of SAS No. 70 from Reports on the Processing of Transactions by Service Organizations to Service Organizations. The amendments in part 3 of this proposed SAS would amend SAS No. 70.

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  Proposed statement on auditing standards : auditing financial instruments : (to supersede Statement on auditing standards no. 81, Auditing investments);Auditing financial instruments : (to supersede Statement on auditing standards no. 81, Auditing investments); Exposure draft (American Institute of Certified Public Accountants), 1999, June 10

  American Institute of Certified Public Accountants. Auditing Standards Board

  This proposed Statement on Auditing Standards (SAS) provides guidance to auditors in planning and performing auditing procedures for financial statement assertions about financial instruments. The Auditing Standards Board (ASB) believes the guidance is needed primarily because of expanding requirements for financial statements to provide information about the fair value of financial instruments and the increasing tendency for entities to use service organizations to help them manage activities involving financial instruments. This proposed SAS: a. Indicates that an auditor may need special skill or knowledge to plan and perform auditing procedures for certain assertions about financial instruments and provides guidance on obtaining that skill or knowledge. b. Provides guidance on inherent risk considerations for assertions about financial instruments. c. Provides guidance on control risk considerations for assertions about financial instruments, including considerations when the entity uses one or more service organizations. d. Indicates that evaluating evidential matter for assertions about financial instruments may require the auditor to use considerable judgment and provides general guidance for those situations. e. Provides general guidance on auditing considerations related to the initial designation of a financial instrument as a hedge and the continued application of hedge accounting. f. Indicates that a service organization's services may affect the nature, timing, and extent of the auditor's substantive tests in a variety of ways. g. Provides examples of substantive tests for the existence or occurrence, completeness, and rights and obligations assertions. h. Provides guidance on substantive tests of valuation assertions that are based on management's intent and ability, including consideration of generally accepted accounting principles that require management to document its intentions. i. Provides guidance on designing substantive tests of valuation assertions based on cost, an investee's financial results, amounts due under a contract, and fair value, including guidance for evaluating management's consideration of the need to recognize impairment losses. This proposed SAS would supersede SAS No. 81, Auditing Investments.

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  Proposed statements on quality control standards : system of quality control for a CPA firm's accounting and auditing practice : (a revision of Statement on quality control standards no. 2, System of quality control for a CPA firm's accounting and auditing practice : and the personnel management element of a firm's system of quality control-- competencies required by a practitioner-in-charge of an attest engagement;System of quality control for a CPA firm's accounting and auditing practice : (a revision of Statement on quality control standards no. 2, System of quality control for a CPA firm's accounting and auditing practice : and the personnel management element of a firm's system of quality control-- competencies required by a practitioner-in-charge of an attest engagement;Personnel management element of a firm's system of quality control-- competencies required by a practitioner-in-charge of an attest engagement; Exposure draft (American Institute of Certified Public Accountants), 1999, June 17

  American Institute of Certified Public Accountants. Auditing Standards Board

  The Auditing Standards Board (ASB) is considering the issuance of two Statements on Quality Control Standards (SQCSs) to provide a CPA firm with improved guidance for establishing and maintaining a quality control system for its accounting and auditing practice. Proposed Statement of Quality Control Standard, System of Quality Control for a CPA Firm's Accounting and Auditing Practice (A Revision of SQCS No. 2) In recent years, the Securities and Exchange Commission (SEC) has successfully brought enforcement actions against individuals who, in the SEC's opinion, did not apply professional standards in his or her role as the concurring partner reviewer on SEC engagements. A task force established by the SEC Practice Section observed that professional standards do not discuss the role of the concurring partner reviewer and recommends that a revision be made to the quality control standards to require a firm to address in its quality control policies and procedures, if applicable, the SEC Practice Section membership requirement for concurring partner reviews on SEC engagements. To assist individuals who wish to comment on the proposed Statement the SEC Practice Section has provided, on its webpage, the concurring partner review membership requirement and related appendix. The Website address of the SEC Practice Section is http://www.aicpa.org/members/div/secps/index.htm. Proposed Statement on Quality Control Standard, the Personnel Management Element of a Firm's System of Quality Control—Competencies Required by a Practitioner-in-Charge of an Attest Engagement The Uniform Accountancy Act (UAA), a model legislative statute and related administrated rules issued by a joint task force of the AICPA and the National Association of State Boards of Accountancy (NASBA), provides certain requirements concerning licensees in public practice that supervise attest services or signs or authorizes someone to sign the accountant's report on the financial statements on behalf of the firm to meet certain experience requirements as required by professional standards. Thus, the issuance of the UAA resulted in consideration of the best method to address this particular requirement of the UAA in professional standards. This in turn resulted in a reconsideration of the Personnel Management element of quality control. A firm would be required to adopt quality control policies and procedures to provide the firm with reasonable assurance that individuals who are responsible for supervising accounting, auditing, and attest engagements and signing or authorizing an individual to sign the accountants report on such engagements meet certain minimum competencies. The Joint Task Force on Quality Control Standards has recommended revisions to the Guide, Quality Control Policies and Procedures for CPA Firms: Establishing Quality Control Policies and Procedures, to provide guidance to firms on implementing and monitoring the requirements outlined in the proposed Statement. The ASB anticipates approving the revised Guide concurrently with the adoption of this proposed Statement and has provided excerpts of the Guide on its Web site to assist individuals who wish to comment on the proposed Statement. The Web site address of the ASB is http://www.aicpa.org/members/div/auditstd. The proposed standards have been developed based on the recommendations of the Joint Task Force on Quality Control Standards, which was formed to develop general guidance for a system of quality control. In addition to ASB representation, the task force is composed of representatives from the SEC Practice Section Peer Review Committee and the AICPA Peer Review Board. The task force wishes to acknowledge the contributions of its observers from NASBA and the Public Oversight Board. The SEC Practice Section Peer Review Committee and the AICPA Peer Review Board have reviewed the exposure drafts and have advised the ASB that, although modifications may need to be made to their peer review programs, these modifications are not expected to result in an expansion of peer review to services provided beyond a firm's accounting and auditing practice. Proposed Statement on Quality Control Standards, System of Quality Control for a CPA Firm's Accounting and Auditing Practice (a Revision of SQCS No. 2) This proposed Statement revises the Engagement Performance element of quality control and will require a firm to establish policies and procedures, cf7 if applicable, to address the SEC Practice Section's membership requirement for concurring partner review on SEC engagements. This revision will now provide a link to professional standards and the membership requirement of the SEC Practice Section. Proposed Statement on Quality Control Standards, the Personnel Management Element of a Firm's System of Quality Control—Competencies Required by a Practitioner-in-Charge of an Attest Engagement This proposed Statement establishes a requirement for a firm to adopt quality control policies and procedures to provide reasonable assurance that individuals responsible for signing attest reports meet certain competencies. The proposed standard focuses on competencies that an individual would be expected to possess for certain kinds of attest engagements. The concept of competency is consistent with the existing Personnel Management element of quality control, which among other matters, requires that "those hired possess the appropriate characteristics to enable them to perform competently" and "work is assigned to personnel having the degree of technical training and proficiency required in the circumstances." These proposed Statements would amend QC Section 20.18 of SQCS No. 2 and provide additional guidance to firms about adoption of policies and procedures relating to the personnel management element of quality control. Issuance of the proposed Statements would also require the adoption of amendments to the Guide Quality Control Policies and Procedures for CPA Firms: Establishing Quality Control Policies and Procedures (the Guide), to be updated. As a result of the issuance of these Statements and updating the Guide, firms with well-established quality control systems should not have to make significant modifications to their policies and procedures.

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  Comment letters on proposed Audit and Accounting Guide, Life and Health Insurance Entities

  American Institute of Certified Public Accountants. Committee on Insurance Accounting and Auditing. Audits of stock life insurance companies

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  Accounting for and reporting of postretirement medical benefit (401(h)) features of defined benefit pension plans : amendment to the AICPA audit and accounting guide, Audits of employee benefit plans; Statement of position 99-2;

  American Institute of Certified Public Accountants. Employee Benefit Plans Committee

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  Proposed statement of position : Accounting for and reporting of certain employee benefit plan investments and other disclosure matters : (proposed amendment to the American Institute of Certified Public Accountants Audit and accounting guide, Audits of employee benefit plans);Accounting for and reporting of certain employee benefit plan investments and other disclosure matters : (proposed amendment to the American Institute of Certified Public Accountants Audit and accounting guide, Audits of employee benefit plans); Exposure draft (American Institute of Certified Public Accountants), 1999, May 17

  American Institute of Certified Public Accountants. Employee Benefit Plans Committee

  This proposed statement of position (SOP) would amend chapters 3 and 4 of the AICPA Audit and Accounting Guide, Audits of Employee Benefit Plans (the Guide). This proposed SOP would amend SOP 94-4, Reporting of Investment Contracts Held by Health and Welfare Benefit Plans and Defined Contribution Plans, and SOP 92-6, Accounting and Reporting by Health & Welfare Benefit Plans. This proposed SOP would simplify disclosures for certain investments and would supersede AICPA Practice Bulletin 12, Reporting Separate Investment Fund Option Information of Defined Contribution Pension Plans. This proposed SOP would accomplish the following: a. Amend paragraph 3.20 of the Guide to eliminate the previous requirement for a defined contribution plan to present plan investments by general type for participant-directed investments in the statement of net assets available for benefits. b. Amend paragraph 3.28(k) and supersede paragraph 3.28(I) of the Guide and supersede Practice Bulletin No. 12 to eliminate the requirement for a defined contribution plan to disclose participant-directed investment programs. c. Amend paragraph 3.28(g) of the Guide to require a defined contribution plan to identify nonparticipant-directed investments that represent five percent or more of net assets available for benefits. d. Amend paragraphs 3.28(p) and 4.57 of the Guide, paragraph 53 of SOP 92-6, and paragraph 15 of SOP 94-4 to require defined contribution plans, including both health and welfare, and pension plans, to disclose benefit-responsive investment contracts in the aggregate rather than by investment fund option. e. Replace exhibits E-l through E-5 in the Guide. This proposed SOP would be effective for financial statements for plan years ending after December 15, 1999. Earlier application will be encouraged for fiscal years for which annual financial statements have not been issued. If the previously required "by-fund" disclosures are eliminated, the reclassification of comparative amounts in financial statements for earlier periods will be required.

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  Guidance to practitioners in conducting and reporting on an agreed-upon procedures engagement to assist management in evaluating the effectiveness of its corporate compliance program; Statement of position 99-1;

  American Institute of Certified Public Accountants. Health Care Pilot Task Force

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  Comment letters on Discussion Paper, Accounting By Life Insurance Enterprises For Deferred Acquisition Costs On Internal Replacements Other Than Those Covered By FASB Statement No. 97

  American Institute of Certified Public Accountants. Insurance Companies Committee

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  Proposed revisions to the AICPA standards for performing and reporting on peer reviews;AICPA standards for performing and reporting on peer reviews;Standards for performing and reporting on peer reviews; Exposure draft (American Institute of Certified Public Accountants), 1999, May 17

  American Institute of Certified Public Accountants. Peer Review Board

  The AICPA Peer Review Board is issuing this exposure draft to update the Standards for Performing and Reporting on Peer Reviews (AICPA, Professional Standards, vol. 2 PR section 100). This proposal: 1. Replaces the term "on-site peer review" with "systemic review" in order to more accurately describe this type of peer review. On a systemic review, the reviewer expresses an opinion on the firm's system of quality control (page 7). 2. Changes the definition of engagements that require a firm to have an on-site (systemic) review. Firms that perform services listed in paragraph 4 of the Standards (which includes review engagements) are required to have a systemic review unless the only services performed are compilations. Under certain circumstances discussed in the Interpretations to the Standards, systemic reviews may be performed at a location other than the reviewed firm's office (page 7). 3. Creates a new type of peer review for firms that only perform compilation engagements called a "report review". An opinion is not issued on a report review. All other firms required to have a peer review have a systemic review. The proposal explains the objectives, basic requirements, engagement selection criteria, reporting requirements and acceptance process for report reviews. With this proposal, "off-site" peer reviews are completely eliminated (page 8). 4. Provides guidance on handling disagreements on report reviews (page 9). 5. Eliminates committee-appointed review teams (CARTs) or association formed review teams for report reviews (page 9). 6. Provides that report reviews are to be performed by only one individual and that individual is designated as the reviewer (page 9). 7. Requires that in order to qualify for service as a reviewer for a systemic review, the reviewer's firm must have received an unmodified peer review report on its system of quality control. A report reviewer must have received an unmodified peer review report on its system of quality control or an unmodified report on its "off-site" peer review (until eliminated). If a firm's most recent review was a report review, then the firm's members are not eligible to perform peer reviews (page 10). 8. Highlights the fact that systemic and report reviews are subject to oversight by the AICPA and the administering entity (page 10). 9. Requires that in order to qualify for service as a peer review committee member with the responsibility for acceptance of reviews, an individual must be associated with a firm that has received an unmodified report on its most recently completed systemic or "off-site" peer review (until eliminated). If the firm's most recent review was a report review, then the member is not eligible for committee service charged with the responsibility for acceptance of any peer reviews (page 11). The changes, if adopted after full consideration of the comments received, will be incorporated into the AICPA Standards for Performing and Reporting on Peer Reviews effective for peer reviews that commence on or after January 1, 2001. Early implementation is not allowed.

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  Omnibus proposal of Professional Ethics Division interpretations and rulings; Exposure draft (American Institute of Certified Public Accountants), 1999, Aug. 2

  American Institute of Certified Public Accountants. Professional Ethics Executive Committee

  1. PROPOSED REVISION OF INTERPRETATION 101-9 UNDER RULE 101: The Meaning of Certain Independence Terminology and the Effect of Family Relationships on Independence [Definition of Member or Member's Firm]; 2. PROPOSED REVISION OF INTERPRETATION 501-1 UNDER RULE 501: Retention of Client Records; 3. PROPOSED REVISION TO RULING 41 UNDER RULE 101: Member as Auditor of Insurance a Financial Services Company that Manages Member's Assets; 4. PROPOSED REVISION TO RULING 109 UNDER RULE 101: Member's Investment in Financial Services Products That Invest in Clients; 5. PROPOSED RULING UNDER RULE 101: Employee Benefit Plan Sponsored by Client

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  Comment letters on Family Relationships Between the Auditor and the Audit Client

  Independence Standards Board

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  Accounting for costs of activities of not-for-profit organizations and state and local governmental entities that include fund raising : amendment to AICPA audit and accounting guides Health care organizations, Not-for-profit organizations, and Audits of state and local governmental units;Amendment to AICPA audit and accounting guides Health care organizations, Not-for-profit organizations, and Audits of state and local governmental units;Costs of activities of not-for-profit organizations and state and local governmental entities that include fund raising : amendment to AICPA audit and accounting guides Health care organization, Not-for-profit organizations, and Audits of state and local governmental units; Statement of position 98-2;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Accounting for the costs of computer software developed or obtained for internal use; Statement of position 98-1;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Comment letters - Proposed SOP, Accounting for Discounts Related to Credit Quality

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Deferral of the effective date of a provision of SOP 97-2, Software revenue recognition; Statement of position 98-4;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Deposit accounting : accounting for insurance and reinsurance contracts that do not transfer insurance risk; Statement of position 98-7;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Draft Exposure Draft: Proposed statement of position : accounting by producers and distributors of films, April 21, 1998; Exposure draft (American Institute of Certified Public Accountants), 1998, April 21

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Modification of SOP 97-2, Software revenue recognition, with respect to certain transactions; Statement of position 98-9;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Proposed statement of position : accounting by producers and distributors of films;Accounting by producers and distributors of films; Exposure draft (American Institute of Certified Public Accountants), 1998, Oct. 16

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

  This proposed Statement of Position (SOP) provides guidance on accounting by producers and distributors of motion picture films. This proposed SOP requires the following: 1. Revenue should be recognized when all of the following conditions are met: a. Persuasive evidence of a sale or licensing arrangement with a customer exists. b. The film is complete and, in accordance with the terms of the arrangement, either has been delivered or is available to be delivered. c. The license period of the arrangement has begun and the customer can begin its exploitation or exhibition. d. The gross revenue is fixed or determinable. e. Collection is reasonably assured. Licensing arrangements that meet all of the above conditions and transfer substantially all of the benefits and risks incident to ownership of the film on an exclusive basis for an individual market and territory should be accounted for as sales. In arrangements that do not meet the "substantially all" and exclusivity requirements, but meet all of the conditions above, revenue should be recognized ratably over the licensing period unless another systematic and rational basis is more representative of the time pattern in which use benefit from the licensed film is diminished, in which case that basis should be used. 2. The costs of producing a film and bringing that film to market consist of production costs, exploitation costs, and participation costs. The present value of participation costs should be accrued when their payment is probable, which is usually determined when the film has been released. Entities should recognize an asset as part of film costs for the initial amount of the participation liability. Production costs and capitalized participation costs should be amortized using the individual-film-forecast-computation method. The individual-film-forecast-computation method requires estimating remaining ultimate gross revenues (original estimates should not exceed 10 years, and amounts included are subject to limitations) as of the beginning of each period. It also requires determining a fraction, the numerator of which is actual gross revenues from the film for the current period and the denominator of which is the estimated unrecognized ultimate gross revenues as of the beginning of the period. This fraction is applied to the unamortized balance of production costs and capitalized participation costs as of the beginning of the period to determine periodic amortization. In this way, in the absence of changes in estimates, production costs and capitalized participation costs are amortized in a manner that yields a constant rate of profit for each film, excluding exploitation costs and other period expenses. Amortization should begin when a film is released and revenues from that film are recognized. Prerelease and early release exploitation costs incurred on a territory-by-territory basis in the theatrical market should be capitalized and amortized over the expected period of exploitation of the film in that theatrical market and territory, not to exceed three months from release date. Capitalized exploitation costs for a particular territory should be amortized in the same ratio that theatrical gross revenues earned in that particular theatrical territory bear to estimated total theatrical gross revenues for that territory for the shorter of (a) three months or {b) the theatrical release period in that territory. All capitalized exploitation costs should be fully amortized by the end of the theatrical release period or three months (whichever is shorter). Exploitation costs should not be accrued in advance of incurrence. After the period leading up to the theatrical release of a film in a territory and the initial three-month period, all exploitation costs should be expensed as incurred. Exploitation costs incurred in connection with the release of a film in markets other than the theatrical market should be expensed as incurred. 3. Unamortized film costs should be reviewed for impairment whenever events or changes in circumstances indicate that the carrying amount of the film may not be recoverable, in accordance with Financial Accounting Standards Board (FASB) Statement No. 121, Accounting for the Impairment of Long-Lived Assets and for Long-Lived Assets to Be Disposed Of. 4. Certain disclosures should be made in the financial statements or notes thereto. This SOP is effective for financial statements for fiscal years beginning after December 1 5, 1 999, with earlier application encouraged. The cumulative effect of changes in accounting principle caused by adopting the provisions of this SOP should be included in the determination of net income in conformity with paragraph 20 of Accounting Principles Board Opinion No. 20, Accounting Changes.

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  Proposed statement of position : accounting by producers and distributors of films; Exposure draft (American Institute of Certified Public Accountants), 1998,August 20

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Reporting on the Costs of Start-up Activities, Draft Dated 1/8/1998, Sent to FASB

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Reporting on the costs of start-up activities; Statement of position 98-5;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee

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  Proposed statement of position : Deferral of the effective date of certain provisions of SOP 97-2, Software revenue recognition, for certain transactions ;Deferral of the effective date of certain provisions of SOP 97-2, Software revenue recognition, for certain transactions; Exposure draft (American Institute of Certified Public Accountants), 1998, Feb. 11

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee and American Institute of Certified Public Accountants. Software Revenue Recognition Working Group

  This proposed Statement of Position (SOP) defers for one year the application of paragraph 10 of SOP 97-2, Software Revenue Recognition, with respect to what constitutes vendor-specific objective evidence of the fair value of the delivered software element in certain multiple-element arrangements that include service elements and that are entered into by entities that never sell the software element separately. All other provisions of SOP 97-2 remain in effect even for the kinds of transactions described in this SOP.

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  Proposed Statement of Position : Modification of the limitations on evidence of fair value in software arrangements : (a proposed amendment to SOP 97-2, Software revenue recognition) ;Modification of the limitations on evidence of fair value in software arrangements : (a proposed amendment to SOP 97-2, Software revenue recognition); Exposure draft (American Institute of Certified Public Accountants), 1998, July 31

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee and American Institute of Certified Public Accountants. Software Revenue Recognition Working Group

  This Statement of Position (SOP) rescinds the second sentences of paragraphs 10, 37, 41, and 57 of SOP 97-2, Software Revenue Recognition, which limited what is considered vendor-specific objective evidence of the fair value of the various elements in a multiple-element arrangement. This SOP also amends certain examples in SOP 97-2 for the rescission of these sentences, and it adds one example. All other provisions of SOP 97-2 remain in effect. This SOP is effective for transactions entered into in fiscal years beginning after December 1 5, 1998.

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  Comment letters on Modification of the Limitations on Evidence of Fair Value in Software Arrangements

  American Institute of Certified Public Accountants (AICPA)

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  Comment letters on Proposed Audit and Accounting Guide “Audits of Investment Companies"

  American Institute of Certified Public Accountants (AICPA)

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  Comment letters on Restricting the Use of an Auditor's Report

  American Institute of Certified Public Accountants (AICPA)

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  Comment letters on Proposed Statement on Standards for Attestation Engagements (SSAE), Amendments to SSAE Nos. 1, 2 and 3.

  American Institute of Certified Public Accountants. Auditing Standards Board

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  Proposed statement on auditing standards : restricting the use of an auditor's report : and amendments of SAS No. 60, communication of internal control related matters noted in an audit, and SAS No. 75, engagements to apply agreed-upon procedures to specified elements, accounts, or items of a financial statement ;Restricting the use of an auditor's report : and amendments of SAS No. 60, communication of internal control related matters noted in an audit, and SAS No. 75, engagements to apply agreed-upon procedures to specified elements, accounts, or items of a financial statement; Exposure draft (American Institute of Certified Public Accountants), 1998, Jan. 26

  American Institute of Certified Public Accountants. Auditing Standards Board

  This proposed Statement provides guidance to auditors to enable them to determine whether an engagement requires a restricted-use report and, if so, what elements to include in that report. Existing auditing standards for engagements requiring restricted-use reports each contain guidance related to the applicable report. This Statement unifies that guidance. This proposed Statement: 1. Describes the circumstances in which the use of an auditor's report should be restricted. 2. Specifies the language to be used in a restricted-use report. 3. Presents the rationale for restricting the use of an auditor's report in each of the circumstances described. 4. Replaces the terms restricted distribution and general distribution with the terms restricted use and general use because auditors are not responsible for controlling the distribution of the reports they issue. 5. Defines the terms restricted use and general use. 6. Clarifies that an auditor may restrict the use of a report that ordinarily is a general-use report. 7. Requires that an auditor restrict a "combined" report if it covers subject matter or presentations that ordinarily do not require a restriction on use and subject matter or presentations that require such a restriction. It permits auditors to include a separate general-use report in a document that also contains a restricted-use report. 8. Amends paragraph 47 of SAS No. 75, Engagements to Apply Agreed-Upon Procedures to Specified Elements, Accounts, or Items of a Financial Statement (AICPA, Professional Standards, vol. 1, AU sec. 622), to permit the inclusion of a separate general-use report in a document containing an agreed-upon procedures report. This amendment does not change the requirement that an auditor restrict a "combined" report if it covers subject matter or presentations that ordinarily do not require a restriction on use and also covers agreed-upon procedures. See appendix A herein for the proposed amandment. 9. Deletes the words or other specified third party from the last sentence of the illustrative report in paragraph 12 of SAS No. 60, Communication of Internal Control Related Matters Noted in an Audit (AICPA, Professional Standards, vol. 1, AU sec. 325), because those words are inconsistent with the guidance in paragraph 10 of SAS No. 60, which does not provide for the addition of other specified third parties as report users. See appendix B herein for the proposed amendment. The proposed Statement would require that conforming changes be made to the guidance in the following documents: 1. SAS No. 51, Reporting on Financial Statements Prepared for Use in Other Countries (AICPA Professional Standards, vol. 1, AU sec. 534); 2. SAS No. 60, Communication of Internal Control Related Matters Noted in an Audit; 3. SAS No. 61, Communication With Audit Committees (AICPA, Professional Standards, vol. 1, AU sec. 380); 4. SAS No. 62, Special Reports (AICPA, Professional Standards, vol. 1, AU sec. 623); 5. SAS No. 75 Engagements to Apply Agreed-Upon Procedures to Specified Elements, Accounts, or Items of a Financial Statement.

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  Proposed statement on standards for attestation engagements : amendments to Statement on standards for attestation engagements no. 1, Attestation standards, Statement on standards for attestation engagements no. 2, Reporting on an entity's internal control over financial reporting, Statement on standards for attestation engagements no. 3, Compliance attestation;Amendments to Statement on standards for attestation engagements no. 1, Attestation standards, Statement on standards for attestation engagements no. 2, Reporting on an entity's internal control over financial reporting, Statement on standards for attestation engagements no. 3, Compliance attestation; Exposure draft (American Institute of Certified Public Accountants), 1998, June 1

  American Institute of Certified Public Accountants. Auditing Standards Board

  An attestation engagement is one in which a practitioner expresses a conclusion about the reliability of a written assertion or statement that is the responsibility of another party. For example, management may state that the entity's internal control over financial reporting is effective as of a certain date or for a specified period of time. Such engagements are performed pursuant to the Statements on Standards for Attestation Engagements (SSAEs) which are promulgated by the Auditing Standards Board (ASB). The type of subject matter that could be addressed by such assertions is broad and includes internal control, compliance with laws and regulations, or other subject matter that could be useful to a decision maker. [A practitioner's engagement to report on historical financial statements is excluded from the scope of the SSAE as such engagements are addressed by the Statements on Auditing Standards (SASs).] The SSAEs were first issued approximately ten years ago. During the past several years, there has been a proliferation of engagements performed pursuant to the SSAEs. The ASB believes that the demand for attest engagements will continue to grow as decision makers increasingly look to CPAs to to enhance the reliability of information on which decision makers rely, beyond historical financial statements. For example, it is expected that many of the services developed by the Assurance Services Executive Committee of the AICPA will include engagements performed pursuant to the SSAEs. The recently developed Web Trust service, which provides assurance about policies and controls of entities offering services or products for sale over the Internet, is an example of such a service provided pursuant to the SSAEs. Additionally, regulators are increasingly looking to obtain assurance from the public accounting profession as to the reliability of an entity's assertions about internal control, compliance with laws and regulations and a variety of other matters. Finally, the SSAEs allow a great deal of flexibility as to the nature and scope of the engagement and provide the profession with many opportunities to help decision makers satisfy their needs. The ASB has undertaken a series of projects to improve the utility of the SSAEs. This exposure draft is one of a series of anticipated exposure drafts resulting from the ASB's efforts to achieve this objective. In order to improve the utility of the SSAEs, the ASB intends to focus on the needs of the decision makers and to identify improvements that can be made to the SSAEs to best meet those needs. This exposure draft focuses primarily on improving the understandability of the conclusions communicated by the practitioner in an attest engagement. Additionally, by clarifying how the Statements on Quality Control Standards (SQCSs) relate to the SSAEs, the ASB is explicitly recognizing the importance of performing attestation engagements within an appropriate framework to ensure that the public accounting profession's reputation for high quality professional services is perpetuated. This proposed SSAE: 1. Would enable the practitioner to report directly to the client his or her conclusion on a specified subject matter, such as internal control, rather than on management's assertion about internal control. 2. Would eliminate the requirement for a separate presentation of management's assertion in certain cases where the assertion is included in the introductory paragraph of the practitioner's report. 3. Would conform the reporting guidance to include reporting elements similar to those required in auditor reports on historical financial statements as contained in SAS No. 58, Reports on Audited Financial Statements (AICPA, Professional Standards, vol. 1, AU sec. 508). 4. Provides guidance on the relationship between the SSAEs and SQCSs. Enabling direct reporting will require amendments to: a. SSAE No. 1, Attestation Standards (AICPA, Professional Standards, vol. 1, AT sec. 100); b. SSAE No. 2, Reporting on an Entity's Internal Control Over Financial Reporting (AICPA, Professional Standards, vol. 1, AT sec. 400); c. SSAE No. 3, Compliance Attestation (AICPA, Professional Standards, vol. 1, AT sec. 500).

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  Proposed statement of position : accounting for discounts related to credit quality;Accounting for discounts related to credit quality; Exposure draft (American Institute of Certified Public Accountants), 1998, Dec. 30

  American Institute of Certified Public Accountants. Discount Accretion Task Force and American Institute of Certified Public Accountants. Accounting Standards Executive Committee

  This proposed Statement of Position (SOP) addresses accounting for differences between contractual and expected future cash flows from an investor's initial investment in certain loans and debt securities (loans) acquired in a transfer when such differences are attributable, at least in part, to credit quality. It includes such loans acquired in purchase business combinations and would apply to all enterprises. The proposed SOP would limit the yield that may be accreted (accretable yield) to the excess of the investor's estimate of undiscounted expected future principal and interest cash flows (expected future cash flows) over the investor's initial investment in the loan. This SOP would require that the excess of contractual cash flows over expected future cash flows (nonaccretable difference) not be recognized as an adjustment of yield, loss accrual, or valuation allowance. The proposed SOP would also prohibit investors from displaying accretable yield and nonaccretable difference in the balance sheet. The proposed SOP would relate subsequent impairment of the loan to the investor's ability to collect all cash flows expected at acquisition. Subsequent increases in expected future cash flows would be recognized prospectively through adjustment of the loan's yield over its remaining life. The provisions of this proposed SOP would be effective for financial statements issued for fiscal years beginning after June 15, 2000.

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  Proposed statement of position : Accounting for and reporting of 401(h) features of defined benefit pension plans : (proposed amendment to the AICPA audit and accounting guide, Audits of employee benefit plans);Accounting for and reporting of 401(h) features of defined benefit pension plans : (proposed amendment to the AICPA audit and accounting guide, Audits of employee benefit plans); Exposure draft (American Institute of Certified Public Accountants), 1998, Sept. 9

  American Institute of Certified Public Accountants. Employee Benefit Plans Committee

  This proposed Statement of Position (SOP) would amend chapters 2, 3, and 4 of the AICPA Audit and Accounting Guide Audits of Employee Benefit Plans (the Guide) with conforming changes as of May 1, 1998. This proposed SOP specifies the accounting for and disclosure of 401(h) features of defined benefit pension plans, by both defined benefit pension plans and health and welfare benefit plans. The proposed SOP requires: a. Defined benefit pension plans to record assets held in a 401(h) account related to health and welfare plan obligations for retirees as both assets and liabilities on the face of the statement of net assets available for pension benefits in order to arrive at net assets available for pension benefits. b. 401 (h) account assets used to fund health and welfare benefits, and the changes in those assets, to be reported in the financial statements of the health and welfare benefit plan. Benefit obligations related to the 401(h) account are also required to be reflected in the health and welfare plan financial statements. c. Defined benefit pension plans to disclose in the notes to the financial statements the nature of the assets related to the 401(h) account, and the fact that the assets are available only to pay retirees' health benefits. d. Health and welfare benefit plans to disclose in the notes to the financial statements the fact that retiree health benefits are funded partially through a 401 (h) account of the defined benefit pension plan. This proposed SOP is effective for financial statements for plan years beginning after December 15, 1998. Earlier application is encouraged. Accounting changes adopted to conform to the provisions of this proposed SOP shall be made retroactively. Financial statements of prior plan years are required to be restated to comply with the provisions of this proposed SOP only if they are presented together with the financial statements for plan years beginning after December 15, 1998. If accounting changes were necessary to conform to the provisions of this proposed SOP, that fact shall be disclosed when financial statements for the year in which this proposed SOP is first applied are presented either alone or with financial statements of prior years.

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  Reporting on management's assessment pursuant to the life insurance ethical market conduct program of the Insurance Marketplace Standards Association; Statement of position 98-6;

  American Institute of Certified Public Accountants. Insurance Companies Committee

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  Statement of Position: Deposit Accounting: Accounting for Insurance and Reinsurance Contracts that Do Not Transfer Insurance Risk; Exposure Draft (American Institute of Certified Public Accountants), 1998, May 20

  American Institute of Certified Public Accountants. Insurance Companies Committee. Deposit Accounting Task Force

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  Proposed audit and accounting guide : Audits of investment companies;Audits of investment companies; Exposure draft (American Institute of Certified Public Accountants), 1998, Sept. 22

  American Institute of Certified Public Accountants. Investment Companies Committee

  This Guide has been written with the assumption that readers are proficient in accounting and auditing in general but not necessarily familiar with the investment company industry. Accordingly, the Guide includes extensive investment company industry background and explanatory material. Chapter 1 provides background information and terminology that is intended to help the reader better understand the industry. Chapters 2 through 4 and chapter 8 focus on the major financial statement components that have unique accounting and auditing requirements for investment companies. Chapter 5 focuses on unique accounting, operational, and auditing aspects of complex capital structures of investment companies, including multiple-class funds, master-feeder funds, and funds of funds. Illustrative financial statements are presented for multiple-class funds, master funds, and feeder funds. Chapter 6 focuses on two distinct aspects of taxes for investment companies: financial statements and other matters, and taxation of regulated investment companies. Chapter 7 focuses on financial statement presentation and disclosure requirements of investment companies. Additional disclosures required by the Securities and Exchange Commission (SEC) for registered investment companies and generally accepted accounting principles (GAAP) disclosure requirements are identified. Illustrative financial statements of a typical open-end management investment company are presented. Chapter 9 provides background information and unique matters related to unit investment trusts. This chapter also contains illustrative financial statements for these entities. Chapter 10 provides background, product design, operational, and regulatory information related to separate accounts of life insurance companies. This chapter also describes auditing considerations and contains illustrative financial statements for these entities. Chapter 11 discusses reports on audited financial statements of investment companies, reports on internal control required by the SEC, reports on processing of transactions by transfer agents, reports on examinations of investment performance statistics, and other reports unique to the investment company industry. Numerous report examples are included in this chapter. Chapter 1 2 provides the basis for conclusions for significant new accounting standards.

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  Proposed Audit and Accounting Guide : Life and health insurance entities;Life and health insurance entities; Exposure draft (American Institute of Certified Public Accountants), 1998, Sept. 4

  American Institute of Certified Public Accountants. Life Insurance Audit Guide Task Force

  The proposed Guide discusses those aspects of accounting and auditing unique to life and health insurance entities and was developed to assist life and health insurance entities in preparing financial statements in conformity with generally accepted accounting principles (GAAP) and to assist independent auditors in auditing and reporting on those financial statements. In addition, the proposed Guide contains significant discussions of statutory accounting practices (SAP) that includes laws, regulations, and administrative rulings adopted by the various states that govern the operations and reporting requirements of life insurance entities. Because this is a category B GAAP document as defined by SAS 69, The Meaning of Present Fairly in Conformity With Generally Accepted Accounting Principles in the Independent Auditor's Report, the inclusion of descriptions of SAP does not elevate SAP into GAAP. This proposed Guide also incorporates accounting and financial reporting requirements issued by the Financial Accounting Standards Board (FASB) and the AICPA Accounting Standards Executive Committee (AcSEC) since the issuance of the AICPA Industry Audit Guide Audits of Stock Life Insurance Companies through April 1 5, 1 998. Also incorporated in this proposed Guide are new auditing standards issued through April 15, 1998, by the AICPA Auditing Standards Board since the issuance of the pronouncements that this Guide would supersede.

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  Comment Letters Received as of July 21,1998 on Exposure Draft Proposed Revisions to the AICPA Standards for Performing and Reporting on Peer Review

  American Institute of Certified Public Accountants. Peer Review Board

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  Proposed revisions to the AICPA standards for performing and reporting on peer reviews;AICPA standards for performing and reporting on peer reviews;Standards for performing and reporting on peer reviews; Exposure draft (American Institute of Certified Public Accountants), 1998, April 20

  American Institute of Certified Public Accountants. Peer Review Board

  The AICPA Peer Review Board is issuing this exposure draft to update the Standards for Performing and Reporting on Peer Reviews (AICPA, Professional Standards, vol. 2, PR sec. 100). This proposal: 1. Expands the definition of an accounting and auditing practice for the purposes of performing and reporting on a peer review to conform with Statement on Quality Control Standards (SQCS) No. 2, System of Quality Control for a CPA Firm's Accounting and Auditing Practice (AICPA Professional Standards, vol. 1, QC sec. 20), thereby including all engagements performed under the Statements on Standards for Attestation Engagements. 2. States that any engagement performed under the Statements on Auditing Standards (SAS) will require an on-site peer review, not just audits of historical financial statements and SAS No. 75, Engagements to Apply Agreed-Upon Procedures to Specified Elements, Accounts, or Items of a Financial Statement (AICPA, Professional Standards, vol. 1, AU sec. 622) engagements to make the standards all inclusive. 3. Replaces the term "owner" with "partner" throughout the peer review standards and adds a footnote defining the term "partner" upon its first use. 4. Replaces the terms "unqualified" and "qualified," which are used to describe the type of peer review report issued with the terms "unmodified" and "modified," respectively. 5. Incorporates Peer Review Standards Interpretation No. 4, "Reviewer Requirements" into the body of the peer review standards. 6. Clarifies that attest engagements should be subject to selection if the date of the report for the engagement falls within the year to be reviewed. 7. Revises the standard language used in the peer review report and letter of comments to make them more easily read and understood by all users. The proposed changes will be incorporated into the AICPA Standards for Performing and Reporting on Peer Reviews effective for peer reviews that commence on or after January 1, 1999. Early implementation is encouraged.

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  Omnibus proposal of Professional Ethics Division interpretations and rulings; Exposure draft (American Institute of Certified Public Accountants), 1998, April 15

  American Institute of Certified Public Accountants. Professional Ethics Executive Committee

  1. PROPOSED REVISION OF THE DEFINITION OF CLIENT UNDER ET SECTION 92; 2. PROPOSED REVISION OF INTERPRETATION 101-2 UNDER RULE 101: Former Practitioners and Firm Independence; 3. PROPOSED REVISION OF RULING NO. 191 UNDER RULE 501 AND RULING NO. 22 UNDER RULE 301: Member Removing Client Files From an Accounting Firm; 4. PROPOSED INTERPRETATION UNDER RULE 101: The Effect of Alternative Practice Structures on the Applicability of Independence Rules; 5. PROPOSED REVISION OF ET SECTION 91.02, Applicability; 6. PROPOSED REVISION OF INTERPRETATION 505-2 UNDER RULE 505: Application of Rules of Conduct to Members Who Operate Own a Separate Business; 7. PROPOSED INTERPRETATION UNDER RULE 505: Application of Rule 505 to Alternative Practice Structures.

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  Omnibus proposal of Professional Ethics Division interpretations and rulings; Exposure draft (American Institute of Certified Public Accountants), 1998, Nov. 16

  American Institute of Certified Public Accountants. Professional Ethics Executive Committee

  1. PROPOSED REVISION OF INTERPRETATION 101-3 UNDER RULE 101: Provision of Other Accounting Services to Clients; 2. PROPOSED RULING UNDER RULE 101 AND RULE 102: Member Is Connected With an Entity That Has a Loan to a Client; 3. PROPOSED REVISION OF INTERPRETATION 102-1 UNDER RULE 102: Knowing Misrepresentations in the Preparation of Financial Statements or Records; 4. PROPOSED RULING UNDER RULE 302: Investment Advisory Services; 5. PROPOSED RULING UNDER RULE 302 AND RULE 503: Commission and Contingent Fee Arrangements With Nonattest Client; 6. PROPOSED REVISION OF INTERPRETATION 501-4 UNDER RULE 501: Negligence in the Preparation of Financial Statements or Records; 7. PROPOSED INTERPRETATION UNDER RULE 501: Failure to File Tax Return or Pay Tax Liability; 8. PROPOSED DELETION OF INTERPRETATION 505-1 UNDER RULE 505: Investment in Accounting Organization

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  Engagements to perform year 2000 agreed-upon procedures attestation engagements pursuant to rule 17a-5 of the Securities Exchange Act of 1934, rule 17Ad-18 of the Securities Exchange Act of 1934, and advisories no. 17-98 and no. 40-98 of the Commodity Futures Trading Commission; Statement of position 98-8;

  American Institute of Certified Public Accountants. Securities Industry Year 2000 Agreed-Upon Procedures Task Force

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  Audits of states, local governments, and not-for-profit organizations receiving federal awards; Statement of position 98-3;

  American Institute of Certified Public Accountants. Single Audit Working Group

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  Comment letters, deferral of the effective date of certain provisions of SOP 97-2, Software revenue recognition, for certain transactions;

  People Soft Bankers Systems

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  Comment Letters to proposed statement on standards for attestation engagements : Management's discussion and analysis;

  American Institute of Certified Public Accountants. Accounting Standards Board

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  Accounting by insurance and other enterprises for insurance-related assessments; Statement of position 97-3;

  American Institute of Certified Public Accountants. Accounting Standards Executive Committee