AICPA FAF Board Comment Letter

The American Institute of Certified Public Accountants (AICPA) is pleased to offer its comments on the Financial Accounting Foundation’s Request for Comments on Proposed Changes to Oversight, Structure, and Operations of the FAF, FASB, and GASB (Proposal).

GASB Funding Source

The AICPA supports a fully funded GASB so that it has appropriate human and financial resources.  Human and financial resources is one of the AICPA Council-approved criteria for assessing standard setting bodies designated under Rule 203 of the Code of Professional Conduct.

The Proposal contains a provision recommending a secure mandatory funding source for the GASB, whereas currently, the GASB is funded based on voluntary contributions.  It is difficult for the AICPA to assess whether it would support a mandatory funding source until we better understand how it would be accomplished.  However, AICPA would be pleased to work with the FAF to assist in exploring alternatives so that the GASB is fully funded.  The AICPA believes this funding initiative can be done exclusively of the FAF proposal, which is why we separate this point from our other comments below.

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