[14649]
April 18, 2002
TO: ACCOUNTING/TREASURERS COMMITTEE No. 17-02
SEC RULES COMMITTEE No. 32-02
RE: ICI COMMENT LETTER ON PROPOSED RESTRUCTURING OF THE FASB
The Institute recently filed a comment letter on the proposed restructuring of the
Financial Accounting Standards Board. The proposed restructuring is intended to allow the
FASB to be more flexible in responding to change and to improve the efficiency of the
accounting standard setting process. The letter is attached and summarized below.
The proposed restructuring would reduce the size of the FASB from seven to five
members, eliminate the super-majority voting requirement for approval of new standards, and
reduce the length of public comment periods on proposed standards. The Institute’s comment
letter notes that one of the seven Board seats has traditionally been reserved for a representative
of the investor community. The Institute’s letter suggests that one or more Board seats be
reserved for representatives of the investor community, even if the Board is decreased from
seven to five members. The Institute’s letter notes that investors are the ultimate consumers of
financial information produced by issuers of securities, and that the Board should be structured
to ensure that their views are afforded due consideration in the standard setting process.
Gregory M. Smith
Director – Operations/
Compliance & Fund Accounting
Attachment
Attachment (in .pdf format)