Comment: interim reporting amendments

In our letter responding to the FASB’s proposal containing narrow-scope amendments to interim reporting, we support the Board’s efforts to clarify disclosure requirements for interim reporting and believe that the proposed amendments are operable and clarify the existing requirements.

Specifically, we support clarifying that the requirements in ASC 270 apply to interim reporting consisting of a full set of financial statements and footnotes to replace the less clear term “interim financial information” that is used in the current guidance. We also support updating ASC 270 with a complete list of interim disclosure requirements, although we note that the methodology used by the Board to arrive at the proposed list may be narrower than companies’ current interpretations, potentially leading to a decrease in some disclosures provided on an interim basis.

However, we believe that the proposed interim disclosure principle would ensure that interim disclosures are materially complete, and we believe that this principle is operable, as it is based on language previously included in SEC requirements. Providing a consolidated list of interim disclosure requirements, along with the interim disclosure principle, may reduce both costs and diversity in practice as well as improve the quality of interim financial reporting, although ensuring that this list remains complete would require ongoing maintenance.

Download our letter to read our comments in full.