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D06228 1 (2013-09-30)

handle is hein.gao/gaobadpug0001 and id is 1 raw text is: L GAO Accountablty *Integrity * Reliability United States Government Accountability Office Washington, DC 20548 September 30, 2013 GASB Scope Financial Accounting Foundation 401 Merritt 7 PO Box 5116, Norwalk, CT 06856-5116 Dear FAF Trustees: Subject: GASB's Scope of Authority: Consultation Process This letter provides the U.S. Government Accountability Office's (GAO) comments on the Financial Accounting Foundation's (FAF) request for comments on GASB's Scope of Authority: Consultation Process. Under the revised proposal, the Trustees of the FAF would decide if certain information is within the Governmental Accounting Standards Board's (GASB) scope of authority. We appreciate the FAF's efforts to address comments received on the original proposal. The independence of the GASB and the effective oversight of the GASB by the FAF are critical elements to effective standard-setting by the GASB. These elements, along with others, are designed to provide assurance that the standards issued by the GASB are generally accepted and in the public interest. As discussed further below, we continue to have concerns that the revised proposal, if implemented, would impair both the independence and oversight of the GASB. The revised proposal appears to continue to include the Oversight Committee and the FAF as part of the GASB's due process. Under certain conditions, the GASB would be required to obtain the approval of the Oversight Committee and perhaps the FAF to proceed with the inclusion of certain types of information in the scope of its projects. For the reasons expressed in our comments in the original proposal, we continue to have concerns that inclusion of the Oversight Committee and the FAF in the due process of the GASB would significantly interfere with the Board's due process and consequently impair its ability to independently set accounting standards that it determines, through due process, are appropriate for users of general purpose external financial reports. We do believe it would be appropriate for the Oversight Committee and the FAF, as part of their oversight role, to determine whether the GASB appropriately followed due process in determining whether information was within its scope. Such due process would include developing

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