Response to FAF Exposure Draft on 'Proposed Changes to Oversight, Structure, and Operations of the FAF, FASB, and GASB'

The Financial Accounting Standards Committee of the American Accounting Association (the Committee) is charged with responding to requests for comments from standard-setters on issues related to financial reporting. The Financial Accounting Foundation (FAF) recently released for public comment, Proposed Changes to Oversight, Structure, and Operations of the FAF, FASB, and GASB (the proposal). Our commentary concerns four issues in the proposal which have the most relevance for accounting standard setting: 1. Reduce the size of the FASB from seven members to five; 2. Retain the FASB simple majority voting requirement; 3. Realign the FASB composition; and 4. Provide the FASB Chair with decision-making authority to set the FASB technical agenda.We disagree with all four of these proposals. The current FASB is set up consistent with a political appointment model rather than a model designed to create an independent standard setting board. The four proposals put forth by the FAF increase the political nature of the FASB, further concentrate decision making power, and make it difficult to get general acceptance of accounting standards. We propose that the FAF move in the opposite direction. In particular, we recommend that the FAF not reduce the FASB size, and adopt a supermajority requirement not a simple voting requirement. If the majority cannot convince other members of the FASB about their views, how can we attain general acceptance of accounting standards in society? We also want a FASB that is open to more diverse views and more democratic. We urge the FAF to increase its engagement with the accounting community instead of becoming more elitist and further concentrating power in the hands of a powerful chairman and a small standard setting board