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Layoff Watch ’26: KPMG Cuts 4% From Consulting

We've got another RIF at KPMG, a consulting cull that went down yesterday (that's Wednesday the 29th for those of you reading this a week from now). Let's start with…

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The Department of War Broke Up with KPMG, KPMG Gives Up Federal Audits Altogether

The other day -- and by the other day we mean like more than a week ago -- we received a text on the tipline that read "KPMG US to…

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KPMG Shoves 10% of Its Audit Partners Out the Door

We're sure you've seen this FT headline floating around today: KPMG to axe 10% of US audit partners. And if you, like most denizens of the internet these days, read…

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PwC Tells Remote Tax Staff to Get Their Butts Into the Office

So much for PwC letting all their people work remotely forever. Remember when that got headlines five years ago? See: PwC Just Announced That You Never Have To Go Back…

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KPMG Plans to Hand Routine Testing Off to AI

Did you happen to see this WSJ article from the other day? In "In This Critical Part of Audits, the Accountant’s Role Is Shrinking Fast," we're given a look into…

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News

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Layoff Watch ’26: KPMG Cuts 4% From Consulting

We've got another RIF at KPMG, a consulting cull that went down yesterday (that's Wednesday the 29th for those of you reading this a week from now). Let's start with…

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Aerial view of the Pentagon

The Department of War Broke Up with KPMG, KPMG Gives Up Federal Audits Altogether

The other day -- and by the other day we mean like more than a week ago -- we received a text on the tipline that read "KPMG US to…

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Monday Morning Accounting News Brief: 990s to Get a Facelift; DOJ Gets Busy Busting Fraud | 4.27.26

Hey. Looking like this is gonna be a short news brief, it was a quiet weekend. In accounting, anyway. In this news briefEveryone Loves an Informative 990The Official IRS Shit…

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Friday Footnotes: Partners Taking Ls; PwC Eats a Big Ol’ Fine; A Post 4/20 IRS Surprise | 4.24.26

Footnotes is a collection of stories from around the accounting profession curated by actual humans and published every Friday at 5pm Eastern. While you're here, subscribe to our newsletter to…

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KPMG exterior with scissors overlay

KPMG Shoves 10% of Its Audit Partners Out the Door

We're sure you've seen this FT headline floating around today: KPMG to axe 10% of US audit partners. And if you, like most denizens of the internet these days, read…

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Technology

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KPMG Plans to Hand Routine Testing Off to AI

Did you happen to see this WSJ article from the other day? In "In This Critical Part of Audits, the Accountant’s Role Is Shrinking Fast," we're given a look into…

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AI Will Be EY Auditors’ New BFF, According to EY

While staff in tax at EY US will soon be spending more time with their flesh-based colleagues due to a return-to-office mandate that requires them in the office for an…

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ICYMI: According to This AI CEO You Won’t Have to Go to Work in a Year

Commence to fantasizing about what you'll do with all that glorious free time when you lose your job to AI in 12-18 months because that's the confident prediction made by…

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Another Early AI Accounting Startup Just Bit the Dust

TIL that early AI accounting platform Botkeeper has died. I found out via this CFO Brew article which pointed to a post on Botkeeper's own site. Turns out r/accounting was…

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KPMG Brings Cheating Into the AI Age By Using AI to Cheat on AI Exams

The image is upside down because Australia. This story sounds like a joke but we assure you it is not. KPMG Australia has expanded KPMG's storied cheating repertoire by being…

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Top Remote Tax and Accounting Candidates of the Week | October 16, 2025

Struggling to Find Remote Accounting or Tax Talent? We’ve Got You Covered.If your firm or internal team is having a tough time sourcing qualified remote tax and accounting professionals, you're…

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Top Remote Tax and Accounting Candidates of the Week | October 2, 2025

Struggling to Find Remote Accounting or Tax Talent? We’ve Got You Covered.If your firm or internal team is having a tough time sourcing qualified remote tax and accounting professionals, you're…

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Top Remote Tax and Accounting Candidates of the Week | September 25, 2025

Struggling to Find Remote Accounting or Tax Talent? We’ve Got You Covered.If your firm or internal team is having a tough time sourcing qualified remote tax and accounting professionals, you're…

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tax hiring season

Top Remote Tax and Accounting Candidates of the Week | September 18, 2025

Struggling to Find Remote Accounting or Tax Talent? We’ve Got You Covered.If your firm or internal team is having a tough time sourcing qualified remote tax and accounting professionals, you're…

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Top Remote Tax and Accounting Candidates of the Week | September 4, 2025

Struggling to Find Remote Accounting Talent? We’ve Got You Covered. If your firm or internal team is having a tough time sourcing qualified remote tax and accounting professionals, you're not…

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Quick Reads

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Here Are Tax and Audit Salaries at Top 25, Top 300, and Regional Firms

Recruiting firm Brewer Morris has released its 2025 US CPA salary guide and should you want to read the whole thing you can request it from them here. Perhaps you,…

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Friendly Reminder Not to Work Yourself to Death For This Profession

Saw this on the bird app yesterday and thought its message would be worth passing along what with 20 days remaining until April 15 and nerves as strained as ever…

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Accounting Firm Abruptly Nopes Out of Tax Season Early (UPDATE)

Ed. note: An earlier version of this article's headline stated the sheriff is investigating. The Alexander County Sheriff's Office informed us they are not investigating, only fielding calls from the…

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This Deloitte Office Has Eliminated Trash Cans at Desks to Make Staff Get Up Off Their Asses

Boston Business Journal wrote an article about Deloitte's new office in Boston and for some reason they chose to lead with this: You won’t find trash cans at the desks…

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The IRS Decided to Troll Tax Pros For 10/15

We realize the decision to run maintenance on IRS systems likely isn't made by anyone who understands deadlines but surely someone who does could inform the IT department of these…

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Top Remote Accounting Freelancers: February 3, 2024

Looking to staff up for a season or hire a freelancer for a project? Accountingfly is ready to partner with you! Gain full access to a pool of highly skilled…

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10 Essential Project Management Principles for Accounting Firms

Every accounting firm struggles with project management, with smaller practices that are rapidly expanding taking the brunt of the damage. As your firm adds new clients, takes on more work,…

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6 Ways Email is Secretly Destroying Your Accounting Firm

Email: The word itself sounds innocent, doesn't it? Kind of like "snail mail," but faster, sleeker, and without the slimy trail. But don't be fooled—email is secretly a sinister beast,…

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Don’t Grow Your Accounting Firm Out of Business! Break Up With These Unscalable Practices Now

Business growth is always a high priority for accounting firms, especially small-to-midsize practices. Take care, though, because growth can be a double-edged sword. If your firm expands too quickly or…

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How a New Graduate Can Pass the CPA Exam (Almost) Before May 2011

This CPA exam candidate changes her name too often on Twitter to be linked to but asks us the following:

I am graduating this fall from [University of San Francisco] with an undergraduate degree in Accounting. My goal is to study and pass the test by May 2011.

I appreciate your input and advice.

First off, I love specific questions like this. If you have them you are, as always, welcome to send them in for future columns. If you have a particular goal (like passing before the 2011 changes or learning how to balance work, family and the exam), I feel better about wasting my time yelling at you because you’re much more likely to succeed. ROI, we all want one.

Anyway.


– Let’s start with the California Board of Accountancy. If you call their exam unit, they will tell you to expect a wait of 4 – 6 weeks for your application to be processed and you’ll get really excited when they cash the $100 application fee check three days after you mailed it. Don’t get excited, that’s the first thing they do (duh, it’s California). In reality, you can expect to wait about 8 weeks from the date you submit your application if you’re freshly graduated and applying with many other accounting grads in the state at the same time. Expect to wait 10 days for your payment coupon and 10 days for your Notice to Schedule once you get your ATT (Authorization to Test). So let’s say your school already posted your degree to your transcripts and you sent in your application today (7/16). You may not get approved until 9/16. Best case scenario they get you approved quickly and you get your ATT on 8/16 (don’t count on it).

Once you have that, it could be another 3 weeks until you are actually scheduling your exams. This year (since your goal is 2011, we’re assuming you’re starting as early as possible before new exam changes hit), the last window of the year will be especially hard to schedule. We’re just guessing on that since everyone seems afraid of CBT-e. It will be interesting to see the actual numbers once they are released.

Get the Hard Stuff Out of the Way – If you can get in one part this year, great. If you had to ask me which one you should take I’d usually say the one that will be hardest for you (since your rolling 18 month window doesn’t start until you actually sit for and pass that first one) but because of the 2011 changes I’m telling most candidates to take FAR. A lot of them are also trying to squeeze in BEC – I imagine they don’t like the idea of written communications and more economics but I could be wrong. Don’t take the easy route, you’ll regret it when you’re trying to pass that last really difficult section you put off and end up losing scores because 18 months came and went.

Don’t Be an Overachiever – I know the old timers will pipe in on this and say back in their day they didn’t have calculators and had to walk uphill both ways in the snow to get to the exam center twice a year to take all 4 parts over 19 1/2 hours but we humbly suggest sitting for no more than two parts per testing window. If you can get in for Q4 2010, you will have one exam done then take two more in Q1 2011 and the last one Q2 2011. So you may not exactly hit your May target but it’s OK to adjust your plans (don’t get mad at the Board of Accountancy but if you want a shortcut around their 8 week application time, get in touch with me) and you can still say you reached your goal.

The only other issue is getting those extra units to actually be licensed under Pathway 2 (the best idea for your own mobility) since you are an undergrad but you can get those in anything and have five years to meet the licensure requirements before you lose your exam scores.

Worry about that later. As for how to study, we’ve talked about CPA review courses, study strategies and things not to do in previous posts. Good luck!

Accounting News Roundup: FinReg Brings Plenty of Change; Some Number Crunching of Goldman’s Fine; ATF: Sin Taxes Rose 41% | 07.16.10

Law Remakes U.S. Financial Landscape [WSJ]
The Journal asked twelves experts about the bill, many of whom are not nearly as impressed as the Deal Professor. “Congress approved a rewrite of rules touching every corner of finance, from ATM cards to Wall Street traders, in the biggest expansion of government power over banking and markets since the Depression.

The bill, to be signed into law soon by President Barack Obama, marks a potential sea change for the financial-services industry. Financial titans such as J.P. Morgan Chase &Group Inc. and Bank of America Corp. may be forced to make changes in most parts of their business, from debit cards to the ability to invest in hedge funds.”

Apple May Offer IPhone Cases, Rebates to Address Flaw [Bloomberg]
Start forming the lines again, “Apple Inc., looking to avoid a recall of the iPhone 4, may give away rubber cases or offer an in-store fix to address a design flaw in the newest version of its top-selling product, according to analysts.

The company, which is holding a news conference at 1 p.m. New York time today, doesn’t plan to announce a recall, a person familiar with the matter said yesterday. Chief Executive Officer Steve Jobs may instead offer the giveaways or refunds to dissatisfied customers, some analysts said.”

Google CFO: Old Spice Is The Future [Tech Crunch]
Written on a horse: “You know you’ve got a viral marketing hit on your hands when the CFO of Google mentions it in an earnings call. Yes, I am talking about the Old Spice YouTube Tweetathon where the bare-chested Old Spice Man addresses people on Twitter via personalized commercials on YouTube.”

Goldman’s SEC Settlement by the Numbers: We Do the Math [ProPublica]
Effectively, it will be paid for by August 1.


AIG Says It Counted as Much as $2.3 Billion of Repos as Sales [Bloomberg BusinessWeek]
Somewhere a former Lehman CFO is screaming, “See, I told you everyone was doing it!”

“American International Group Inc., the bailed-out insurer, said it classified as much as $2.3 billion of repurchase agreements and $3.8 billion of securities- lending transactions as sales in calculating quarterly results.

In late 2008, ‘certain of AIG’s counterparties demanded significantly higher levels of collateral to enter into repurchase agreements, which resulted in sales rather than collateralized-financing’ treatment under accounting guidelines, the New York-based insurer said in an April 13 letter to the Securities and Exchange Commission released today. The accounting didn’t materially affect any ratios or metrics the company publicly disclosed, AIG said in the letter.”

‘Sin Tax’ Revenue Surges [TaxProf Blog]
“The Treasury Department’s Alcohol and Tobacco Trade and Tax Bureau has released its Fiscal Year 2009 Annual Report, detailing a 41% increase (to $20.6 billion) in the amount of “sin taxes” on alcohol, tobacco, firearms, and ammunition collected by the federal government. Most of the $6 billion revenue increase resulted from the higher tobacco taxes included in the Children’s Health Insurance Reauthorization Act of 2009. Firearms and ammunition excise tax collection rose 45%, the largest annual increase in the agency’s history.”

KV Pharma Names New CFO; Hunt for Auditor, Signs of an Internal Control System Begins

The AP reports that K-V Pharm named Tom McHugh as their new CFO today which is good news for KV but could be some serious bad news for Tom.

As you may recall, things haven’t been as good as you could ask for over at KV this year – directors, auditors and executives are all bolting for the door and someone has to make a run at this thing. One of those lucky ducks is Tom McHugh:

K-V Pharmaceutical Co. on Thursday named Chief Accounting Officer Thomas McHugh as its new chief financial officer, replacing Stephen Stamp after three months.

The company said McHugh becomes its CFO effective immediately. McHugh served as the company’s interim CFO from September 2009 until April 2010. He was named chief accounting officer in February.

So it sounds like Tommy probably knows the place well enough but he still gets to fix all this:

“Material weaknesses have been identified and included in management’s assessment in the areas of entity-level controls (control awareness, personnel, identification and addressing risks, monitoring of controls, remediation of deficiencies and communication of information), financial statement preparation and review procedures (manual journal entries, account reconciliations, spreadsheets, customer and supplier agreements, stock-based compensation, Medicaid rebates and income taxes) and the application of accounting principles (inventories, property and equipment, employee compensation, reserves for sales allowances and financing transactions).”

And find an auditor! Since KPMG quit, the hunt is on for a new one, so hopefully there’s someone in St. Louis willing to help them out because…the NYSE kinda, sorta took notice that the company didn’t file their 10-K on time and well, that’s a no-no. Just ask Koss.

So the good money is probably is riding against Tom but we’re rooting for you buddy. Turn this ship around!

K-V Pharma replaces CFO after 3 months [AP]

The SEC Should Be Careful Not to Spend All $550 Million in One Place

Hopefully they’ll spread it around, you know, with lifetime memberships to: ladyboyjuice.com, kinkycomments.com, sexyavatars.net, cafebuckskin.blogspot.com et al.

Goldman Sachs has agreed to pay $550 million to the Securities and Exchange Commission, the largest penalty ever paid by a Wall Street firm, to settle charges of securities fraud linked to mortgage investments.

Under the terms of the deal, Goldman will pay $300 million in fines to the Treasury Department, with the rest serving as restitution to investors in the mortgage-linked security. Goldman will not admit wrongdoing, though it will admit that its marketing materials for the investment “contained incomplete information.”

That doesn’t sound nearly as fun but we understand a few people may have gotten hurt on this deal.

Goldman Settles With S.E.C. for $550 Million [NYT]

Lots of Appointing Going on at KPMG Today

Namely Jim Liddy the new Vice Chair – Audit; Tom Duffy – National Managing Partner – Audit; Scott Ozanus Vice Chair – Tax; and Jeff LeSage National Managing Partner – Tax.


And on such a grand occasion, John Veihmeyer gets to say lots of nice things about all these guys even though at least one of these guys is probably gunning for his position.

Jimbo: “Jim Liddy has a remarkable record of providing deep insights to financial service clients and companies in other sectors about their businesses and growth strategies, and is a proven leader. I’m confident that with his intense focus on audit quality, Jim will build on the strong audit practice that Henry Keizer created over the past five years to help ensure KPMG’s continued success.”

Tom: “As the newly named national managing partner – audit, Tom Duffy will team with Jim Liddy to lead our audit practice. Tom has considerable industry experience and a proven track record of delivering audit quality and exceptional service to our clients.”

Scottie: “We’re looking forward to Scott’s leadership during this important period for our tax practice and KPMG’s clients – as companies cope with legislative and regulatory changes, and seek clarity in complex challenges related to transfer pricing, restructuring, renewable energy and a variety of other areas.”

Jeff: “As the new national managing partner – tax, Jeff LeSage will team with Scott Ozanus to lead tax, bringing global tax experience, industry insight and outstanding client service skills to this important role.”

Congrats gentlemen. Not sure if these particular positions get you 18 with Phil or not but we’re sure they are sweet gigs all the same.

KPMG Appoints Jim Liddy Vice Chair – Audit [PR Newswire]
KPMG LLP Appoints Scott Ozanus Vice Chair – Tax [PR Newswire]

It’s Possible That the IRS Is Partly to Blame for Postal Workers Going Postal

Our favorite corner of the Federal bureaucracy, the Treasury Inspector General for Tax Administration, has come out with a new report today that admits that the IRS current method of sending notices and letters is costing us – taxpayers – millions because so much of it is undeliverable. This happens for various reasons, including nearly 25% of instances where recipients may or may not have physically threatened their mail carrier.


Press release (our emphasis):

TIGTA Report: Current Practices Are Preventing a Reduction in the Volume of Undeliverable Mail

The Internal Revenue Service’s (IRS) current method of sending notices and letters is costing taxpayers millions of dollars because it results in a large amount of undeliverable mail, according to a report publicly released today by the Treasury Office of the Treasury Inspector General for Tax Administration (TIGTA).

The IRS sends out approximately 200 million notices and letters each year to individual and business taxpayers and their representatives at a cost of $141 million. In 2009, approximately 19.3 million of those mailings were returned to the IRS at an estimated cost of $57.9 million.

TIGTA assessed whether the IRS can reduce the volume of undeliverable mail. Its review of a random sample of 331 notices and letters returned to the IRS found that 37 percent were undeliverable because of invalid or nonexistent addresses; 35 percent had the wrong address; 24 percent were refused by the taxpayer or the taxpayer was not at home to receive the certified or registered mail; and four percent were returned for other reasons.

TIGTA recommended that the IRS allow taxpayers to submit a change of address over the telephone and improve its systems for identifying known bad addresses. TIGTA also recommended implementing a standardized procedure for processing undeliverable mail.

“The Internal Revenue Service needs to take advantage of the latest technologies and systems now available to cut down on undeliverable mail, thereby saving the taxpayers money,” said J. Russell George, the Treasury Inspector General for Tax Administration.

In response, the IRS agreed with all of TIGTA’s recommendations and has begun the process of planning to implement them.

So, in other words, the IRS is partly responsible for several instances of the following:

Are Ernst & Young and PwC Neck and Neck in the Compensation Race?

From the mailbag:

I heard some scoop and wanted to share with my fellow indentured servants in the big 4 field. Word on the street is that P-dubs gave 10% raises to staff 2s becoming senior 1s (early promote) and 16% raises to staff 3s becoming senior 1s.

However, P-dubs doesn’t hand out the 5k bonus that Uncle Ernies offers to its staff 2s becoming senior 1s. I’d like to see how EY will top this, per an earlier promise from a partner that EY raises will be higher than P-dubs (maybe can some low performing partners?). In addition, the variance between average performers and high performers at P-dubs is only .6% (not significant at all).


If you forgot what this is referring to, back in April we reported a tip out of the Ernstiverse that a partner had claimed that the raises at E&Y would beat PwC’s. The reports out of PwC have been better than expected, although not for everyone.

So if this partner’s prognostication holds up, how will they pull it off down the stretch? Seems like a good question. Conversations are going on right now and the official news will reportedly be out in a couple weeks.

Since we’ve got half of the Big 4 involved here we’ll just mention that the belly aching at KPMG is in full force on the bonus front but maybe there’s hope for a strong move down the stretch?

As for Deloitte, apparently communication has occurred for promotions but it sounds like word on comp could be more than a month out. If you’ve got the scoop get in touch with the details and discuss this four horse race but as it stands right now, it looks as if PwC has E&Y by a nose.

More Than a Few People Didn’t Heed the ABA’s Advice re: “Fair Value Sucks” Letters to the FASB

Just last week we mentioned the American Bankers Association and its efforts to undermine the FASB’s latest fair value proposal that, in the ABA’s mind, could bring down civilization as we know it.

Because of this danger, the ABA encouraged “investors” through email and on its website to write individual letters to the FASB, expressing their displeasure with the worst idea in the modern history of double-entry accounting. We say “investors” because the ABA not-so-subtly asked everyone (i.e. who felt the overwhelming urge to write Bob Herz & Co.) to refer to themselves as such.

Further, the ABA provided a template of a letter to send to the Board for the “investors,” however, it did warn to resist using the example as their own because A) this is far too important and telling the FASB that fair value pains you in the deepness of your soul and takes food out of your children’s mouths will be a far more effective narrative; and B) the FASB hates form letters. HATES. So much so that Bob Herz rips up all his gold stars that he gives for the constructive letters he receives and then your unoriginal ass gets negative points.

The group urges investors to “write your own letter — the FASB does not appreciate ‘form’ letters, and often discounts them in their analyses.”

Simple enough, right? Well, maybe. But In his column today, Jonathan Weil gives an example of one ABA soldier that wasn’t very good at following instructions:

Among the letter writers was Terry L. Stevens of Francesville, Indiana, who identified himself as a bank investor, as the ABA had suggested. He didn’t mention that he also is chief financial officer and executive vice president of Alliance Bank, a closely held lender in Francesville with $270 million of assets.

“As a bank investor, of utmost importance to me regarding the banks in which I own stock is their financial position, and transparent financial reporting is key in order for me to make investment decisions,” Stevens’ letter said. “With this in mind, I am writing to express my deep concerns and opposition to the portion of the proposal that requires all financial instruments to be marked to market.”

Stevens didn’t write those words himself. He copied them verbatim from a sample letter the ABA posted on its Web page. So, too, did a bunch of other bankers who submitted comment letters to the FASB opposing its proposal, notwithstanding the ABA’s warning that they shouldn’t do cut-and-paste jobs.

This had to be a mistake, right? This is far too important of an issue to the banks of this country that a mishap like this could just happen. Bankers are responsible people that take this stuff very seriously and would never risk going through the motions just to serve at the whims of their lobby’s voice…would they?

Stevens told me he didn’t have time to write his own letter from scratch. “The points that I grabbed out of their paragraphs did a good job of explaining how I felt about the situation,” he said.

Oh.

Stealth Bankers Bomb as Anti-Reform Crusaders [Jonathan Weil/Bloomberg]

Accounting News Roundup: Congress Still Stalling on Tax Bill; ‘Most Americans Have Not Planned Well for Their Futures’; Deloitte’s Schroeder Joining FASB | 07.15.10

As Tax Cuts’ Expiration Date Nears, Little Consensus [WSJ]
“Lawmakers are negotiating a tax bill, but appear increasingly likely to wait until after the November election to take any final action that could anger voters—either by raising taxes, or by cutting them and thereby deepening deficits. Congress ultimately could decide to extend current tax levels for just a few months, leaving the issue for the next Congress to settle. Another option is a short-term extension of a year or two, avoiding for now the huge cost to the Treasury of a permanent extension. It’s even possible Congress might fail to take any action this year.”

From Jail, Conrad Black Fights $71 Million Tax Bill [Forbes]
“Imprisoned former media baron Conrad M. Black is fighting a $71 million bill from the U.S. Internal Revenue Service, which says from 1998 to 2003 he filed no tax returns and paid absolutely nothing on $120 million in taxable income.

In a previously unreported lawsuit in U.S. Tax Court, Black, now serving a six-and-a-half-year-sentence in a Florida federal prison, is challenging the IRS’ demands and asserting the income in question wasn’t taxable in the U.S.”

Americans More Optimistic on Economy Than Their Own Finances, Survey Says [Bloomberg]
Who said Americans only think about themselves? “Americans are generally hopeful, and much of the economic news leads us to conclude that we are out of the recession and a double dip is unlikely,” said Robert Glovsky, chair of the CFP Board and director of Boston University’s program for financial planners. “With that said, most Americans have not planned well for their futures.”

Harvey Golub Resigns as AIG Chairman [WSJ]
“A weeks-long standoff between the chairman and chief executive of government-controlled American International Group Inc. ended Wednesday, when Chairman Harvey Golub resigned, saying, ‘I believe it is easier to replace a chairman than a CEO.’

Mr. Golub’s decision marks a victory for Robert Benmosche, the company’s hard-charging chief, who chafed under Mr. Golub’s oversight. Mr. Benmosche had told the board their working relationship was ‘ineffective and unsustainable,’ Mr. Golub said in his resignation letter.”

FASB hires expert to review how new rules perform [Reuters]
“Mark Schroeder, a recently retired senior partner at Deloitte & Touche [DLTE.UL], will serve as the board’s first “post-implementation review leader” and also serve a similar role for the Governmental Accounting Standards Board, FASB said.

The hiring of Schroeder is one of the big steps that FASB has taken to formalize its process for review of how new standards are performing. Banks and investors had complained during the financial crisis that FASB’s new rules on mark-to-market accounting had contributed to freezing the credit markets, but there was no formal process for reviewing the rules.”