An Examination of Comment Letters Filed in the U.S. Financial Accounting Standard‐Setting Process by Institutional Interest Groups

Abstract

With the advent of some form of IASC‐type harmonized accounting standards likely, it has been suggested that they are likely to be based to a large extent on U.S. accounting standards promulgated by the FASB. This study of the content of comments filed on twenty controversial FASB accounting standards by four institutions in the United States is timely. Those comments are assumed to represent the views of financial‐statement users, attestors and preparers: FEI, IMA, AIMR, and AICPA. The adopted standards’ requirements are also examined in the context of these comments to provide insights about accounting characteristics on which the FASB has aligned with different interest groups. These characteristics include uniformity in accounting methods, disclosure, volatility in financial reporting, and conservatism. The results indicate that AIMR, in representing users, is the most constant in its positions. The two preparer organizations (FEI and IMA) took user‐oriented positions on some issues, but showed a strong tendency to oppose costly disclosures and requirements associated with volatility. Comments from the AICPA were diverse but the study revealed an overall bias toward user views. Overall, the FASB aligned most closely with users and the AICPA. FASB tended to adopt standards that led to greater uniformity but compromised on costly disclosures and requirements associated with volatility and conservatism.

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