October 17, 2021

The Two Best Comment Letters Written to the FASB You’ll Ever Read

Last month we told you about how the American Bankers Association encouraged anyone that disagreed with the FASB’s proposed fair value rule to write a letter telling Herz & Co. how much the proposal suind enough to provide a template for said “FASB Blows” correspondence so the anti-fair value crowd could get the gist of what needed to be said.

The ABA did warn, however, that the FASB hates, loathes, DETESTS form letters, so in order to make a valid point, it was advisable to not simple slap your name in the appropriate place but to articular your own special brand of hatred for the FASB.

As you may recall, many ABA groupies did not heed this warning, which no doubt resulted in Bob Herz and the rest of the Norwalk team using the letters to stoke their mid-summer weenie roast bonfire.

As disappointed as the ABA must have been with the lack of originality, we were sent this shining example that has been making the rounds at the Big 4 (or so we’re told). Our guess is that this is more of what the ABA had in mind:

FASB1

Bravo, James C. Blaine. Bravo. You are most definitely into the brevity thing. You have, presumably, made the ABA proud. But wait, there is a pro-fair value letter worthy of these pages.


Granted, it was written back in May but Brian Cowell is no less passionate than Mr Blaine:

FASB2

Nicely done, both of you. Everyone take note.

Last month we told you about how the American Bankers Association encouraged anyone that disagreed with the FASB’s proposed fair value rule to write a letter telling Herz & Co. how much the proposal sucked. The ABA was kind enough to provide a template for said “FASB Blows” correspondence so the anti-fair value crowd could get the gist of what needed to be said.

The ABA did warn, however, that the FASB hates, loathes, DETESTS form letters, so in order to make a valid point, it was advisable to not simple slap your name in the appropriate place but to articular your own special brand of hatred for the FASB.

As you may recall, many ABA groupies did not heed this warning, which no doubt resulted in Bob Herz and the rest of the Norwalk team using the letters to stoke their mid-summer weenie roast bonfire.

As disappointed as the ABA must have been with the lack of originality, we were sent this shining example that has been making the rounds at the Big 4 (or so we’re told). Our guess is that this is more of what the ABA had in mind:

FASB1

Bravo, James C. Blaine. Bravo. You are most definitely into the brevity thing. You have, presumably, made the ABA proud. But wait, there is a pro-fair value letter worthy of these pages.


Granted, it was written back in May but Brian Cowell is no less passionate than Mr Blaine:

FASB2

Nicely done, both of you. Everyone take note.

Latest Accounting Jobs--Apply Now:

Have something to add to this story? Give us a shout by email, Twitter, or text/call the tipline at 202-505-8885. As always, all tips are anonymous.

Related articles

Friday Footnotes: Deloitte Sued; RSM Sued; PwC Not Sued But Incompetent | 10.15.21

‘What do you actually do?’: Redditors scratch heads at consulting firms [Yahoo News] We’ve often wondered about this too. Deloitte Workers Sue Over ‘Astronomical’ 401(k) Fees [Law360] Deloitte workers slapped the accounting giant with a proposed class action in New York federal court, claiming the company allowed two multibillion-dollar retirement plans to get saddled with […]

[UPDATED] PwC Australia Diversity and Inclusion Manager Who Mocked Chinese Accents Had to Be Told You Aren’t Supposed to Mock Chinese Accents

[Updated original post from Sept. 28 with additional information on PwC Australia’s internal investigation. Update is at the bottom of this article.] Australian Financial Review has a blockbuster of an exclusive this morning, one that involves “a human resources executive dressed as a bat from Wuhan” and a senior manager of diversity and inclusion mocking […]