Comment letters

Related documents

•   Recognition and Measurement of Financial Assets and Financial Liabilities (May 15, 2013) (310 KB)

  Comment letter to FASB on proposed Accounting Standards Update (ASU), Recognition and Measurement of Financial Assets and Financial Liabilities. 

•   Notice of Filing of Proposed Rule Change to Require that Listed Companies Have an Internal Audit Function (March 29, 2013) (39 KB)

  Comment letter on the U.S. Securities and Exchange Commission’s Notice of Filing of Proposed Rule Change to Require that Listed Companies Have an Internal Audit Function issued by the NASDAQ Stock Market LLC.

•   Exposure Draft: Novation of Derivatives and Continuation of Hedge Accounting - Proposed Amendments to IAS 39 and IFRS 9 (March 21, 2013) (197 KB)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft 2013/2 Novation of Derivatives and Continuation of Hedge Accounting - Proposed Amendments to IAS 39 and IFRS 9.

•   Exposure Draft: Classification and Measurement: Limited Amendments to IFRS 9 - Proposed amendments to IFRS 9 (2010) (March 21, 2013) (225 KB)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9 - Proposed amendments to IFRS 9 (2010).

•   Exposure Draft: Clarification of Acceptable Methods of Depreciation and Amortisation - Proposed amendments to IAS 16 and IAS 38 (March 8, 2013) (158 KB)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft Clarification of Acceptable Methods of Depreciation and Amortisation - Proposed amendments to IAS 16 and IAS 38.

•   Exposure Draft: Recoverable Amount Disclosures for Non-Financial Assets - Proposed Amendments to IAS 36 (March 8, 2013) (158 KB)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft 2013/1 Recoverable Amount Disclosures for Non-Financial Assets - Proposed Amendments to IAS 36.

•   Exposure Draft: Share of Other Net Asset Changes - Proposed amendments to IAS 28 (March 8, 2013) (159 KB)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft ED/2012/3 Equity Method: Share of Other Net Asset Changes - Proposed amendments to IAS 28.

•   Exposure Draft: Annual Improvements to IFRSs 2011-2013 Cycle (February 8, 2013) (176 KB)

  Grant Thornton International Ltd comments on the International Accounting Standards Board's Exposure Draft ED/2012/2 Annual Improvements to IFRSs 2011-2013 Cycle.

•   Exposure Draft, Proposed Revised Interpretation of Professional Ethics Division: Subordination of Judgment by a Member (January 17, 2013) (281 KB)

  Comment letter on the AICPA Professional Ethics Executive Committee recently issued Exposure Draft, Proposed Revised Interpretation of Professional Ethics Division: Subordination of Judgment by a Member.

•   Omnibus Proposal of Professional Ethics Division: Proposed Revised and New Interpretations and Proposed Deletion of Ethics Rulings (December 17, 2012) (218 KB)

  Comment letter on the AICPA Professional Ethics Executive Committee’s Exposure Draft, Omnibus Proposal of Professional Ethics Division: Proposed Revised and New Interpretations and Proposed Deletion of Ethics Rulings.

•   Exposure Draft, Omnibus Proposal of Professional Ethics Division: Interpretations and Definitions dated September 19, 2012 (December 5, 2012) (209 KB)

  Comment letter on the American Institute of Certified Public Accountants (“AICPA”) Professional Ethics Executive Committee (“PEEC”) recently issued Exposure Draft (“ED”), Omnibus Proposal of Professional Ethics Division: Interpretations and Definitions.

•   COSO Internal Control Integrated Framework and Compendium (December 4, 2012) (275 KB)

  Comment letter on the Committee of Sponsoring Organizations of the Treadway Commission’s (COSO) “Post Public” Exposure Draft: Internal Control – Integrated Framework and the accompanying Draft for Discussion Internal Control over External Financial Reporting: A Compendium of Approaches and Examples.

•   Disclosure Framework (November 30, 2012) (91 KB)

  Comment letter to FASB on the Invitation to Comment, Disclosure Framework.

•   Post-implementation Review: IFRS 8 Operating Segments (November 1, 2012) (201 KB)

  Comment letter on the International Accounting Standards Board's (the Board) Request for Information Post-implementation Review: IFRS 8 Operating Segments (the Request for Information).

•   Omnibus Statement on Auditing Standards (November 1, 2012) (61 KB)

  Comment letter on the proposed Statement on Auditing Standards (SAS), Omnibus Statement on Auditing Standards – 2012.

•   Commission Statement in Support of Convergence and Global Accounting Standards (October 31, 2012) (139 KB)

  Comment letter on the SEC Staff paper, Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers: Final Staff Report.

•   Financial Instruments (Topic 825): Disclosures about Liquidity Risk and Interest Rate Risk (September 25, 2012) (100 KB)

  Comment on the proposed Accounting Standards Update (proposed Update), Financial Instruments (Topic 825): Disclosures about Liquidity Risk and Interest Rate Risk.

•   Put Options Written on Non-controlling Interests (September 7, 2012) (196 KB)

  Grant Thornton International Ltd comment letter on the IFRS Interpretations Committee’s Draft Interpretation DI/2012/2: Put Options Written on Non-controlling Interests (the DI). 

•   Exposure Draft ED/2012/1 - Annual Improvements to IFRSs 2010-2012 Cycle (August 21, 2012) (248 KB)

  Comment letter from Grant Thornton International Ltd on the International Accounting Standards Board's (the Board) Exposure Draft ED/2012/1 Annual Improvements to IFRSs 2010-2012 Cycle (the ED).

•   Draft IFRIC Interpretation Levies Charged by Public Authorities on Entities that Operate in a Specific Market (August 21, 2012) (203 KB)

  Comment letter from Grant Thornton International Ltd on the IFRS Interpretations Committee‟s Draft Interpretation DI/2012/1: Levies Charged by Public Authorities on Entities that Operate in a Specific Market (the DI).

•   PCAOB Rulemaking Docket Matter No. 38 (May 31, 2012) (131 KB)

  Comments on the Public Company Accounting Oversight Board’s Proposed Auditing Standard – Related Parties, Proposed Amendments to Certain PCAOB Auditing Standards Regarding Significant Unusual Transactions, and Other Proposed Amendments to PCAOB Auditing Standards.

•   PCAOB Rulemaking Docket Matter No. 39 (April 30, 2012) (59 KB)

  Comment on the Public Company Accounting Oversight Board’s (PCAOB or Board) Proposed Amendments to Conform the Board’s Rules and Forms to the Dodd-Frank Act and Make Certain Updates and Clarifications.

•   Reform of Federal Policies Relating to Grants and Cooperative Agreements (April 30, 2012) (53 KB)

  Comment on the proposed Reform of Federal Policies Relating to Grants and Cooperative Agreements; cost principles and administrative requirements (including Single Audit Act) released by the Office of Management and Budget (OMB).

•   Public Exposure Draft, Internal Control – Integrated Framework (April 25, 2012) (410 KB)

  Comment letter on the Committee of Sponsoring Organizations of the Treadway Commission’s (COSO) Public Exposure Draft, Internal Control – Integrated Framework (Exposure Draft).

•   EFRAG and OIC Discussion Paper: Accounting for Business Combinations under Common Control (April 24, 2012) (183 KB)

  Grant Thornton International Ltd (Grant Thornton International) comment letter on the European Financial Reporting Advisory Group’s (EFRAG) Discussion Paper: Accounting for Business Combinations Under Common Control (the Paper).

•   ESMA Consultation Paper ‘Considerations of Materiality in Financial Reporting’(March 15, 2012) (197 KB)

  Grant Thornton International comment letter on ESMA Consultation Paper ‘Considerations of Materiality in Financial Reporting.’

•   Exposure Draft Revenue from Contracts with Customers (ED/2011/6), Revised Exposure Draft of a proposed Accounting Standards Update of Topic 605 (March 9, 2012) (387 KB)

  Comment letter from Grant Thornton International Ltd and its US member firm, Grant Thornton LLP, on the International Accounting Standards Board (IASB) and Financial Accounting Standards Board (FASB) Exposure Draft (revised Exposure Draft of a proposed Accounting Standards Update of Topic 605) Revenue from Contracts with Customers (the ED).

•   PCAOB Rulemaking Docket Matter No. 30 (February 29, 2012) (102 KB)

  Comments on the Public Company Accounting Oversight Board’s Proposed Auditing Standard Related to Communications with Audit Committees; Related Amendments to PCAOB Standards; and Transitional Amendments to AU sec. 380.

•   Proposed Accounting Standards Update (ASU), Real Estate—Investment Property Entities (Topic 973) (February 16, 2012) (75 KB)

  Comment on the proposed Accounting Standards Update (ASU), Real Estate—Investment Property Entities (Topic 973).

•   Proposed Accounting Standards Update (ASU), Financial Services—Investment Companies (Topic 946) Amendments to the Scope, Measurement, and Disclosure Requirements (February 16, 2012) (67 KB)

  Comment on the proposed Accounting Standards Update (ASU), Financial Services—Investment Companies (Topic 946) Amendments to the Scope, Measurement, and Disclosure Requirements.

•   Proposed Accounting Standards Update (ASU), Consolidation (Topic 810): Principal versus Agent Analysis (February 15, 2012) (115 KB)

  Comment on the proposed Accounting Standards Update (ASU), Consolidation (Topic 810): Principal versus Agent Analysis.

•   The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern (January 31, 2012) (41 KB)

  Comments to the Auditing Standards Board of the AICPA in response to the proposed redrafted Statement on Auditing Standards, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern.

•   Plan to Establish the Private Company Standards Improvement Council (January 13, 2012) (151 KB)

  Comments on the the Plan to Establish the Private Company Standards Improvement Council (“the Plan”).

•   PCAOB Rulemaking Docket Matter No. 29, Improving the Transparency of Audits: Proposed Amendments to PCAOB Auditing Standards and Form 2 (January 9, 2012) (94 KB)

  Comments on the Public Company Accounting Oversight Board’s Proposed Amendments to PCAOB Auditing Standards and Form 2.

•   Exposure Draft Investment Entities (ED/2011/4) (December 22, 2011) (232 KB)

  Comments on the International Accounting Standards Board's (the Board) Exposure Draft Investment Entities (ED/2011/4).

•   Exposure Draft – Government Loans: Proposed amendments to IFRS 1 (December 22, 2011) (149 KB)

  Comments on the International Accounting Standards Board's (the Board) Exposure Draft Government Loans: Proposed amendments to IFRS 1(the ED).

•   PCAOB Rulemaking Docket Matter No. 37, Concept Release on Auditor Independence and Audit Firm Rotation (December 14, 2011) (81 KB)

  Comments on the Public Company Accounting Oversight Board’s (PCAOB or Board) Concept Release on Auditor Independence and Audit Firm Rotation.

•   Exposure Draft Q&As 2011 IFRS for SMEs (November 28, 2011) (175 KB)

  Grant Thornton International Ltd is pleased to comment on the SME Implementation Group's (the SMEIG's) Exposure Drafts (EDs) of the Q&As listed. We have considered the EDs, as well as each accompanying draft Basis for Conclusions.

•   Request for Views - Agenda Consultation 2011 (November 28, 2011) (193 KB)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's (the Board) Request for Views – Agenda Consultation 2011 (the Request for Views).

•   Omnibus Proposed New and Revised Interpretations and Proposed Deletions of Ethics Rulings - AICPA Professional Ethics Division (November 23, 2011) (166 KB)

  Comment letter on the proposed revision to Interpretation 203-1, “Departures from Established Accounting Principles,” proposed new Interpretation 203-5, “financial Statements Prepared Pursuant to Financial Reporting Frameworks Promulgated by Bodies Designated by Council, and proposed revision to Interpretation 501-1, “Response to requests by Clients and Former Clients for Records“ that were approved for exposure by the Professional Ethics Executive Committee of the American Institute of Certified Public Accountants.

•   Exposure Draft – Improvements to International Financial Reporting (October 19, 2011)

  Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft Improvements to International Financial Reporting Standards (the ED). We have considered the ED as well as the accompanying draft Basis for Conclusions.

•   Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements (September 30, 2011)

  Comments on Public company Accounting Oversight Board’s Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements and Related Amendments to PCAOB Standards.

•   Proposed Standards for Attestation Engagements Related to Broker and Dealer Compliance or Exemption Reports required by the Commission (September 12, 2011)

  Comments on Public Company Accounting Oversight Board’s (PCAOB or Board) proposed attestation standards, Examination Engagements Regarding Compliance Reports of Brokers and Dealers, and Review Engagements Regarding Exemption Reports of Brokers and Dealers, and the related amendments.

•   Proposed Auditing Standard, Auditing Supplemental Information Accompanying Audited Financial Statements (September 12, 2011)

  Comment on the Public Company Accounting Oversight Board’s (PCAOB or Board) proposed auditing standard, Auditing Supplemental Information Accompanying Audited Financial Statements, and related amendments.

•   File No. S7-23-11, Broker-Dealer Reports (August 26, 2011) (58 KB)

  Grant Thornton LLP appreciates the opportunity to comment on the U.S. Securities and Exchange Commission’s (SEC or Commission) proposed amendments to the broker-dealer financial reporting rule under the Securities Exchange Act of 1934 (Annual Reporting Amendments), and we respectfully submit our comments and recommendations thereon. Any capitalized terms herein that are undefined have the same meaning assigned to them in the proposed rule.

•   Commission Statement in Support of Convergence and Global Accounting Standards (July 29, 2011)

  Comment on the May 26, 2011 SEC Staff Paper, Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers: Exploring a Possible Method of Incorporation.

•   Omnibus Statement on Auditing Standards - 2011 (July 1, 2011)

  Comment on the proposed Statement on Auditing Standards Omnibus Statement on Auditing Standards - 2011 approved for exposure by the Auditing Standards Board of the American Institute of Certified Public Accountants.

•   Assurance Engagements on Greenhouse Gas Statements (June 17, 2011)

  Comment on the proposed International Standard on Assurance Engagements 3410, Assurance Engagements on Greenhouse Gas Statements.

•   Exposure Draft Q&As 2011/02; 03 and 04 IFRS for SMEs Section 1 (June 16, 2011)

  Comment on the SME Implementation Group's Exposure Drafts of several Q&As. We have considered the EDs, as well as each accompanying draft Basis for Conclusions.

•   Omnibus Proposal of AICPA Professional Ethics Division: Interpretations and Definition (June 14, 2011)

  Comment on the American Institute of Certified Public Accountants Professional Ethics Executive Committee recently issued Exposure Draft, Omnibus Proposal of AICPA Professional Ethics Division: Interpretations and Definition.

•   Omnibus Proposal of AICPA Professional Ethics Division: Interpretations and Rulings (June 7, 2011)

  Comment on the American Institute of Certified Public Accountants’ Professional Ethics Executive Committee’s recently issued Exposure Draft, Omnibus Proposal of AICPA Professional Ethics Division: Interpretations and Rulings, which proposes certain revisions to the independence and ethics requirements and related guidance.

•   The Evolving Nature of Financial Reporting: Disclosure and Its Audit Implications (June 6, 2011)

  Grant Thornton International Ltd is pleased to have the opportunity to comment on the Discussion Paper, The Evolving Nature of Financial Reporting: Disclosure and Its Audit Implications, approved for publication by the International Auditing and Assurance Standards Board.

•   Proposed International Standard on Review Engagements 2400 (Revised) (May 20, 2011)

  Comment on the proposed International Standard on Review Engagements 2400 (Revised), Engagements to Review Historical Financial Statements, approved for exposure by the International Auditing and Assurance Standards Board of the International Federation of Accountants.

•   The Use of the Accountant’s Name in a Document or Communication Containing Unaudited Financial Statements That Have Not Been Compiled or Reviewed (May 9, 2011)

  Comment on the proposed Statement on Standards for Accounting and Review Services, The Use of the Accountant’s Name in a Document or Communication Containing Unaudited Financial Statements That Have Not Been Compiled or Reviewed, approved for exposure by the Accounting and Review Services Committee of the American Institute of Certified Public Accountants.

•   Alert as to the Intended Use of the Auditor’s Written Communication (April 29, 2011)

  Comment on the proposed Statement on Auditing Standards (SAS), Alert as to the Intended Use of the Auditor’s Written Communication, approved for exposure by the Auditing Standards Board (Board) of the American Institute of Certified Public Accountants.

•   Discussion Paper: Selected Issues about Hedge Accounting (April 25, 2011)

  Our primary concern with the IASB’s hedge accounting proposal is its divergence from the FASB’s proposal on the same topic (and vice versa). As we have noted in previous comment letters to the Boards, regarding both the FASB’s financial instruments proposal and the IASB’s Exposure Draft on hedge accounting, we believe the goal of developing converged guidance in this area is of utmost importance.

•   Consultative Report on the Review of the IFRS Foundation's Governance (April 6, 2011)

  Comment on the IFRS Foundation Monitoring Board's Consultative Report on the Review of the IFRS Foundation's Governance.

•   Supplementary Document: Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities: Impairment (April 1, 2011)

  Comment on the International Accounting Standards Board’s and the Financial Accounting Standards Board’s Supplementary Document, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities: Impairment.

•   Use of the IFRS for SMEs in parent’s separate financial statements (April 1, 2011)

  Grant Thornton International Ltd is pleased to comment on the SME Implementation Group's Exposure Draft of Q&A 2011/01 Use of the IFRS for SMEs in parent’s separate financial statements.

•   Exposure Draft Hedge Accounting (March 8, 2011)

  Grant Thornton International Ltd is pleased to comment on the International Accounting Standards Board's Exposure Draft Hedge Accounting.

•   Comment to SEC on Conflict Minerals (March 2, 2011)

  Comments related to the implementation of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requiring regulations related to the disclosure and reporting obligations concerning the use of conflict minerals from the Democratic Republic of the Congo and adjoining countries of issuers that file reports pursuant to Sections 13(a) or 15(d) of the Securities Exchange Act of 1934.

•   IFRS Foundation Strategy Review (February 24, 2011)

  Grant Thornton International Ltd welcomes the opportunity to respond to the IFRS Foundation's Paper for Public Consultation Status of Trustees' Strategy Review.

•   Proposed Temporary Rule for an Interim Program of Inspection Related to Audits of Brokers and Dealers (February 14, 2011)

  Comment on the Public Company Accounting Oversight Board’s  Proposed Temporary Rule for an Interim Program of Inspection Related to Audits of Brokers and Dealers.

•   Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country (February 3, 2011)

  Comment on the proposed revised Statement on Auditing Standards, Financial Statements Prepared in Accordance With a Financial Reporting Framework Generally Accepted in Another Country, approved for exposure by the Auditing Standards Board of the American Institute of Certified Public Accountants.

•   Request for Views on Effective Dates and Transition Methods (January 28, 2011)

  Grant Thornton International Ltd is pleased to respond to the International Accounting Standards Board's Request for Views on Effective Dates and Transition Methods.