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1 Record ID: Question Text Response Status * Please select the type of entity or individual responding to this feedback form. Other, please specify (Specified) User * Please provide contact information for any follow-up questions. Organization * First name * Middle initial Last name * address * Phone number Would the concepts for developing line items in this proposed chapter encompass the information appropriate for the Board to consider for developing financial statements that would assist resource providers in their decision making? Are there concepts that should be added or removed? (Filled in as Follows:) Mission College Gregory Mostyn fqmifa7316@sbcglobal.net Paragraphs P32-P49, particularly as summarized in paragraph P37 and discussed in P38-P49 provide a comprehensive summary of factors that potentially could be reflected in various line item presentations, and that would potentially benefit (capital providing) users with information enhancement. However, the important considerations of the constituent aggregate cost-benefit factor and the related factor of a resulting and possibly evolving complexity are omitted. The conceptual framework does not address whether specific characteristics of a single contract There does not appear to be any inherent reason that the factors could not in principle be applied. However, the practicality of the application would be a function of the nature and clarity (or lack thereof, either intentional or not) of any given contract.

2 should be recognized, measured, and presented separately or grouped with other contracts. Similarly, the conceptual framework does not address whether specific characteristics of multiple contracts should be recognized, measured, or presented separately or combined with other contracts. Some Board members believe that the factors developed in paragraph PR37 could be potentially helpful in addressing these issues when considering changes to the definitions of the elements or recognition criteria. Could the Board use any of the factors in paragraph PR37 of this Exposure Draft to help make decisions about combining contracts or separating specific aspects of a single contract when recognizing, measuring, and presenting items? Please provide any additional Proposed Concepts Statement 8, Chapter 7, ( The Statement ) is a useful and thoughtful review of key elements and issues regarding general-purpose financial

3 comments on the proposed chapter: statement presentation. Within this context, The Statement contemplates a wide scope of topics including reporting objectives and uses, information provided, general design characteristics, and perceived constraints. The Statement is of major significance because as indicated in the preface it would be used as a framework for developing future standards that determine presentation (P4). The following observations are offered for consideration: Widespread Effect and Impact: Any party that uses general-purpose financial statements will potentially be affected by Concepts Statement 8, Chapter 7. For example, if The Statement is utilized as a basis for development of a standard that mandates a change in existing general-purpose financial statement design, it will affect all stakeholders and users of generalpurpose financial statements. This effect would be greater than any other single standard. Such a widespread effect creates a very important issue, which is aggregate costbenefit. If a revised design creates material change or complexity in existing general-purpose financial statement design, widespread costs would be incurred that would include areas such as software and system redesign, retraining at many levels, student education, possible restatements for comparative reports, and costs related to misunderstandings. This is not to say that change in bad and the Luddites were correct; rather, that the present ambiguity of aggregate benefit vs. cost should be given very serious consideration in this impactful statement. The Statement makes only a single reference to cost (PR14) as part of a discussion of footnotes:...as well as the cost constraint, which is a standards-level consideration. First, the assertion that cost falls solely within the purview of the standards-level is contradicted by the repeated references to cost in existing concepts statements (see examples below). Secondly, cost of information is a determinative factor in how and whether any given information should exist; clearly, an existential idea of elemental importance and scope. The Statement refers repeatedly to providers of capital resources as the users of financial information, e.g....potential investors, lenders, and other creditors in making decisions about providing resources to the entity. (PR5),

4 and therefore, as the key beneficiaries with improved return on investment and/or reduced risk, possibly (but not necessarily) resulting in some reduction in cost of capital. In other words, a direct benefit accompanied by a generalized trickle-down benefit. While it is unquestionably true that capital providers are the most influential engine of economic growth and users of financial statements, it is also true that there are many other users, at least in number if not in access to capital, that would also would bear cost in the aggregate. As an example, CON 1 (Para. 24) and CON 4 (Para. 29) refer to, among many examples: managers, employees, taxing authorities, regulatory authorities, labor unions, researchers, teachers, and students. Would benefits to them exceed their financial costs and time-value costs? In fact, for some stakeholders, current reporting might be completely satisfactory; new data arrangements emphasizing different factors and minimizing prior ones could even be adverse. Such considerations do not, but should significantly, appear in The Statement so that they can be reflected in possible future standards. Reference to cost considerations do appear in other concepts statements, e.g. The information provided by financial reporting involves a cost to provide and use, and generally the benefits of information provided should be expected to at least equal the cost involved. (CON 1, Para. 23). Also: Ultimately, a standard-setting body has to do its best to meet the needs of society as a whole when it promulgates a standard...and it must be aware constantly of the calculus of costs and benefits...the Board cannot cease to be concerned about the cost-effectiveness of its standards. To do so would be a dereliction of its duty and a disservice to its constituents. (CON2, Summary of Principal Conclusions) Finally, ongoing simplification efforts should also serve as cautionary examples of the need to seriously consider the cost-benefit issue. Responses resulting in the development of the Small Business Advisory Committee, the Private Company Financial Reporting Committee, and later the ongoing efforts of the Private Company Council (themselves all incurring costs) illustrate the real effects of cost issues imposed on significant elements of the constituency. The current FASB simplification initiative provides further illustration. Why not incorporate this valuable experience into the framework in a material and significant way? Utilization of Technology: The Statement does not address the key concept of application of technology as a means of achieving the stated

5 overall objective of assessing the prospects for future cash flows. Importantly, XBRL technology exits, and is in use, that can address resource providers analytical needs in virtually an unlimited number of ways. It would be fair to say, using the language in the proposed framework, that XBRL materially enhances the usability of financial statements. Issues identified in The Statement such as aggregation and disaggregation, line items, totals and subtotals, homogeneous groupings based on various factors, frequency, and predictability are all addressable with XBRL technology. Data can be extracted and reformatted and reused in unlimited ways. Because the Securities and Exchange Commission requires XBRL reporting, the stated issues are already currently addressable as they relate to numerous larger users of capital resources. Furthermore, XBRL is also in use by other entities and the taxonomy is expanding. (Even for small companies? A recent AICPA survey reported that among 1,300 small public companies complying with SEC requirements, for 69% of the respondents the conversion cost was $10,000 or less.) Moreover, XBRL will be in greater use by the time possible future standards are developed on the basis of the proposed framework. As well, the FASB has since 2010 been primarily responsible for the continuing development of US GAAP XBRL Financial Reporting Taxonomy. Although The Statement focuses primarily on the financial statement analytical needs of capital providers, XBRL has many other applications. For example, taxonomy can be developed for taxes, regulatory filings, various forms of business and non-business reports, and extracting, aggregating, and analyzing consumer data. Secondly, software applications are now available for general users that allow the use of familiar tools such as spreadsheets for extracting XBRL data, creating templates, inserting formulas, and performing analysis. These tools are also available in cloud-based platforms. As a result, customized information becomes available to any entity identifying it is a priority (i.e., perceived benefit exceeds cost). A conceptual framework is a basic structure for the development of future standards. However, it can equally serve to reduce cost and complexity in those standards. As acknowledged, there are a wide variety of potential formats that could be useful to providers of capital. These will be difficult to adequately and fairly address in a single standard; the potential for a growing complexity is great. However, a framework that identifies and supports the concept of application of technology (using XBRL as one

6 example) on a user-defined basis as a means of supplementing current presentation standards could greatly reduce or even eliminate the potential for complexity in future standards - and avoid an imposition of unnecessary costs for many. As well, the FASB has for a number of years been involved in the development and application of XBRL taxonomy. Why would this long experience not help to inform concepts presented in a proposed framework? Please provide any comments on the electronic feedback process: Below is a printable summary of your responses to the questions in this feedback form. You can revise your responses by clicking the "Back" button. All comments received constitute part of the FASB's public file. The FASB will make all comments publicly available by posting them to the Online Comment Letters portion of its website. If you are finished providing comments, click the 'Submit' button at the bottom of this page. Excellent availability and process. However, paragraph formatting does not appear to function in the (following screen) review box. Not Answered Not Answered