January 23, 2015

Ms. Teresa Polley

President and Chief Executive Officer
Financial Accounting Foundation
401 Merritt 7
P.O. Box 5116
Norwalk, CT 06856-5116
Mr. Russ Golden
Chairman
Financial Accounting Standards Board
301 Merritt 7
P.O. Box 5116
Norwalk, CT 06856-05116
Re: Financial Accounting Foundation Strategic Plan (Working Draft, December
2014)
Dear President Polley and Chairman Golden:
The U.S. Chamber of Commerce1 (Chamber) created the Center for Capital
Markets Competitiveness (CCMC) to promote a modern and effective regulatory
structure for capital markets to fully function in a 21st century economy. To achieve
these goals, the CCMC has supported the development of robust financial reporting
systems and encouraged efforts to improve standards and reduce complexity.
The CCMC appreciates the opportunity to comment on the Financial Accounting
Foundation (FAF) Strategic Plan Working Draft (Strategic Plan), as developed by
FAF, the Financial Accounting Standards Board (FASB), and the Governmental
Accounting Standards Board (GASB). The CCMC believes that the Strategic Plan is a
positive and continuous evolution of past efforts by the FAF and FASB to broaden
The U.S. Chamber of Commerce (the Chamber) is the worlds largest federation of businesses and associations,
representing the interests of more than three million U.S. businesses and professional organizations of every size and in
every economic sector. These members are both users and preparers of financial information.
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Ms. Teresa Polley

Mr. Russ Golden
January 23, 2015
Page 2
outreach and maintain the transparency and communication needed for evidence based
standard setting. The CCMC believes that this update and refinement of prior mission
statements provides clarity on long-range goals allowing for greater feedback and
accountability.
The Strategic Plan articulates a vision for FAF, FASB, and GASB to be
recognized leaders in financial accounting and reporting. In particular, the Strategic Plan
rests on the core principle that FAF, FASB, and GASB will be best-in-class in their
rolessetting accounting standards of the highest quality through a comprehensive
process that exemplifies a commitment to integrity, objectivity, independence,
transparency, inclusiveness, and leadership.2 This vision also explicitly recognizes, among
other matters, the importance of ensuring that the costs incurred by financial statement
preparers to provide information to financial statement users are justified by the benefits
provided.3 The CCMC welcomes the best-in-class goal, and believes that vigorous
commitment to cost-benefit analysis will be an important element in achieving it.
The Strategic Plan states that accounting standards will be developed first
considering the best interests of investors and others who participate in the U.S. capital
marketsand other markets around the world that use or reference Generally Accepted
Accounting Principles (US-GAAP). The CCMC accepts this focus but urges that it
also include for consideration the other components that are stipulated in the Exchange
Act and the Securities and Exchange Commission (SEC) follows in rule writing
namely, capital formation and competition, in addition to investor protection.
The Strategic Plan goes on to emphasize FASB will collaborate and cooperate
with other national standard setters, and will participate in and shape the development of
International Financial Reporting Standards (IFRS).4 The CCMC has supported the
efforts of FASB and International Accounting Standards Board (IASB) on the
convergence of accounting standards. While the CCMC continues to believe that there
should ultimately be a single set of world class global accounting standards, we also
recognize the importance of considering the interests of the U.S. capital markets, those
that use or rely on U.S. GAAP and the mission of FASB to meet those needs.
See Strategic Plan, page 1.
Ibid.
4 See Strategic Plan, page 5.
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Ms. Teresa Polley

Mr. Russ Golden
January 23, 2015
Page 3
The Strategic Plan includes building and maintaining trust with stakeholders
among the top four priorities.5 In this regard, the Strategic Plan specifically recognizes
the importance of outreach activitiessuch as field testing, site visits, roundtables,
hearings and the likebefore implementing accounting standards, as well as postimplementation reviews. The CCMC applauds this dedication to outreach activities and
urges particular focus on pre-implementation initiatives that have not historically been
routine in accounting standard setting, such as field testing and site visits. We also
commend FASBs efforts to dialogue with a variety of stakeholders to have an informed
standard setting process and believe that additional efforts to enhance outreach and
transparency will further improve standard setting.
Finally, the CCMC is pleased that FASB, like the SEC, is determined to simplify
financial reporting standards, reduce the complexity and overlap in financial reporting
and disclosure requirements, and mitigate disclosure overload. While the four priorities
identified in the Strategic Plan are consistent with and accommodate these efforts, the
CCMC suggests that the Strategic Plan may benefit from a more explicit recognition of
them. The CCMC has had discussions with the SEC and others to move forward on
disclosure effectiveness to ensure that corporate disclosures meet the needs of investors
and businesses in a 21st century economy. The CCMC recently issued a report to
propose changes to disclosures and will issue an additional report on the subject of
disclosure effectiveness later this year.6
We anticipate that our initiative will complement the FASBs initiative and we
hope to have further discussions with the FAF and FASB to assist in this effort.
Sincerely,

Tom Quaadman

See Strategic Plan, pages 4-5.

The Chambers report was released on July 29th, 2014 and can be found here:
http://www.centerforcapitalmarkets.com/wp-content/uploads/2014/07/CCMC_Disclosure_Reform_Final_7-2820141.pdf
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