This is our third comment letter in the last two years and we hope the third time is a charm.

The time is now for a separate Private Company Standards Board that is solely focused on the financial reporting needs of the US small business community.

It should be structured as indicated in the FAF's own Blue Ribbon Panel when released in their report dated January, 2011. It should be distinct but linked to FASB and beyond a FASB veto. The latest recommendation from FAF to create a PCSIC is too similar to the PCFRC which was formed several years ago and did not work (see FIN 48 & 46(r)). That is the gist of our comments and those of thousands more CPAs representing CFOs, controllers, bankers, and auditors of America's middle market companies.

We (MACPA) created an Accounting Standards Task Force and responded to the FAF BRP in our whitepaper here. We also exposed this issue and its almost forty year background to thousands of CPAs across Maryland over the past year. They overwhelmingly agreed with us (and the FAF BRP).

The deadline for comment closed this past Saturday with almost 6,500 comment letters asking for the Financial Accounting Foundation (FAF) to nix its latest plan to create a Private Company Standards Improvement Council (PCSIC) in favor of the recommendations from its own Blue Ribbon Panel. 

Here is the latest from the Journal of Accountancy. You can see the comment letters here and the AICPA letters from their Private Company Standards site are listed seperately here. Even Congress weighed in with a letter from Senator Levin (MI) that was noteworthy (in a bad way!) and reported on in CFO Magazine here.

We applaud the FAF for its efforts to start this conversation (again!). We appreciate their efforts to get widespread input. We hope they are listening, this time.