The assurance professionals at RSM recognize the importance of active participation in shaping industry standards and regulatory policies that govern our business landscape. Responding to standard setters and regulatory bodies, nationally and internationally, through comment letters serves as a powerful avenue for us to contribute our valuable insights, expertise, and recommendations. By engaging in this proactive dialogue, we can impact the development of fair and effective regulations that not only align with our organizational values but also foster a conducive environment for growth and innovation.
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Comment letters to regulatory agencies
Comment letters serve as a powerful tool for us to contribute valuable insights, expertise and recommendations.
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Audit
Financial reporting
July 1, 2025
Proposed Statement on Auditing Standards, External Confirmations, AICPA Auditing Standards Board – February 27, 2025
May 9, 2025
Proposed Statement on Standards for Attestation Engagements, Scope Limitations in a Review Engagement (the proposed SSAE).
June 13,2025
Proposed ASB Strategic Plan 2026–2030, AICPA Auditing Standards Board
December 16, 2024
Exposure Draft, Proposed Statement on Standards for Accounting and Review Services, Applicability of AR-C Section 70 to Financial Statements Prepared as Part of a Consulting Services Engagement
June 1, 2024
Exposure Draft, Proposed Peer Review Standards Update No. 2, Reviewing A Firm’s System of Quality Management and Omnibus Technical Enhancements
January 23, 2024
Proposed Criteria for the Presentation of the Sufficiency of Assets for Redemption Specific to Asset-Backed Fiat-Pegged Tokens
August 21, 2023
Exposure Draft, Proposed new definition of publicly traded entity and revised definition of public interest entity, AICPA Professional Ethics Division – June 15, 2023
June 15, 2023
AICPA proposed new and revised interpretations related to fees (the Exposure Draft)
May 15, 2023
AICPA proposed revised interpretation Uniform CPA Examination and Continuing Professional Education
December 22, 2022
AICPA Exposure Draft, Proposed Criteria for a Description of the Content of Quality Control Materials (QCM) and the Content of QCM Related to the Relevant Standards and Interpretive Guidance
October 10, 2022
AICPA on the Exposure Draft, Maintaining the Relevance of the Uniform CPA Examination – Aligning the Exam with the CPA Evolution Licensure Model
September 1, 2022
AICPA Professional Ethics Division’s on the Exposure Draft, Proposed New and Revised Definitions and Interpretations - Compliance Audits
July 5, 2022
AICPA Professional Ethics Executive Committee on the Exposure Draft, Proposed Revisions Related to Officers, Directors and Beneficial Owners
June 17, 2022
AICPA Auditing Standards Board proposed Statement on Auditing Standards (SAS), Special Considerations – Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-to Auditors)
May 11, 2022
AICPA Auditing Standards Board proposed Statement on Auditing Standards (SAS), Amendment to AU-C Section 935
December 14, 2021
AICPA Exposure Draft, Proposed Changes to AICPA Standards for Performing and Reporting on Peer Reviews – Clarification of AICPA Standards for Performing and Reporting on Peer Reviews
June 23, 2024
Financial Accounting Foundation’s (FAF or Foundation) Request for Comment concerning the Foundation’s Review of the Private Company Council (PCC or Council)
June 26, 2025
feedback on the Financial Accounting Standards Board (FASB or Board) 2025 Invitation to Comment (ITC)
April 10, 2025
Feedback on the Financial Accounting Standards Board’s (FASB or Board) Proposed Accounting Standards Update, Codification Improvements, (the proposed ASU or proposal)
April 8, 2025
Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Environmental Credits and Environmental Credit Obligations (Topic 818) (proposed Update or proposal)
March 21, 2025
Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Interim Reporting (Topic 270)-Narrow-Scope Improvements (proposed Update or proposal)
March 19, 2025
Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Government Grants (Topic 832): Accounting for Government Grants by Business Entities (proposed Update or proposal)
January 27, 2025
Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software (proposed Update or proposal)
January 14, 2025
Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses for Accounts Receivable and Contract Assets for Private Companies and Certain Not-for-Profit Entities (proposed Update or proposal)
December 10, 2024
Feedback on the Financial Accounting Standards Board’s proposed Accounting Standards Update (ASU), Business Combinations (Topic 805) and Consolidation (Topic 810): Determining the Accounting Acquirer in the Acquisition of a Variable Interest Entity.
November 22, 2024
Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Derivatives and Hedging (Topic 815): Hedge Accounting Improvements (proposed Update).
November 13, 2024
Comments on the Public Company Accounting Oversight Board’s (PCAOB) Proposed Auditing Standard – Designing and Performing Substantive Analytical Procedures and Amendments to Other PCAOB Standards.
October 18, 2024
Comments on FASB's proposed Accounting Standards Update (ASU), Derivatives and Hedging (Topic 815) and Revenue from Contracts with Customers (Topic 606): Derivatives Scope Refinements and Scope Clarification for a Share-Based Payment from a Customer in a Revenue Contract (proposed Update).
March 11, 2024
Accounting Standards Update, Debt—Debt with Conversion and Other Options (Subtopic 470-20): Induced Conversions of Convertible Debt Instruments
February 29, 2024
Proposed Statement of Financial Accounting Concepts - Concepts Statement No. 8, Conceptual Framework for Financial Reporting Chapter 6: Measurement
October 20, 2023
FASB proposed Income Statement - Reporting Comprehensive Income = Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses
August 22, 2023
FASB proposed Accounting Standards Update (proposed ASU), Financial Instruments—Credit Losses (Topic 326), Purchased Financial Assets
July 7, 2023
FASB proposed Accounting Standards Update (ASU), Compensation—Stock Compensation (Topic 718): Scope Application of Profits Interest Awards (proposed Update or proposal)
June 2, 2023
FASB proposed Accounting Standards Update (ASU), Intangibles—Goodwill and Other—Crypto Assets (Subtopic 350-60), Accounting for and Disclosure of Crypto Assets
May 24, 2023
FASB proposed Accounting Standards Update (ASU), Income Taxes (Topic 740): Improvements to Income Tax Disclosures (proposed Update or proposal)
February 17, 2023
FASB proposed Statement of Financial Accounting Concepts - Concepts Statement No. 8, Conceptual Framework for Financial Reporting Chapter 5: Recognition and Derecognition
January 11, 2023
FASB proposed Statement of Financial Accounting Concepts - Concepts Statement No. 8, Conceptual Framework for Financial Reporting Chapter 2: The Reporting Entity
January 11, 2023
FASB proposed Accounting Standards Update, Leases (Topic 842): Common Control Arrangements
December 22, 2022
FASB Accounting Standards Update Business Combinations—Joint Venture Formations (Topic 805-60): Recognition and Initial Measurement
December 14, 2022
FASB proposed Accounting Standards Update, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures (proposed Update or proposal)
October 14, 2022
FASB Accounting Standards Update, Investments–Equity Method and Joint Ventures (Topic 323): Accounting for Investments in Tax Credit Structures Using the Proportional Amortization Method
June 3, 2022
FASB proposed Accounting Standards Update, Reference Rate Reform (Topic 848) and Derivatives and Hedging (Topic 815): Deferral of the Sunset Date of Topic 848 and Amendments to the Definition of the Secured Overnight Financing Rate Overnight Index Swap Rate
March 9, 2022
FASB proposed Accounting Standards Update, Liabilities—Supplier Finance Programs (Subtopic 405-50): Disclosure of Supplier Finance Program Obligations
January 28, 2022
FASB proposed Accounting Standards Update, Interim Reporting (Topic 270): Disclosure Framework—Changes to Interim Disclosure Requirements
December 23, 2021
FASB’s proposed Accounting Standards Update, Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures
December 20, 2024
Securities and Exchange Commission [Release No. 34-101723; File No. PCAOB-2024-07] Public Company Accounting Oversight Board; Notice of Filing of Proposed Rules on Firm Reporting; PCAOB Rulemaking Docket Matter No. 055
December 20, 2024
Securities and Exchange Commission [Release No. 34-101724; File No. PCAOB-2024-06] Public Company Accounting Oversight Board; Notice of Filing of Proposed Rules on Firm and Engagement Metrics and Related Amendments to PCAOB Standards; PCAOB Rulemaking Docket Matter No. 041
July 23, 2024
SECURITIES AND EXCHANGE COMMISSION [Release No. 34-100430; File No. PCAOB-2024-03] Public Company Accounting Oversight Board; Notice of Filing of Proposed Rules on Amendments Related to Aspects of Designing and Performing Audit Procedures that Involve Technology-Assisted Analysis of Information in Electronic Form
July 16, 2024
Comments on the final standard adopted by the PCAOB on A Firm’s System of Quality Control and Related Amendments to PCAOB Standards
June 14, 2024
Comments on the PCAOB's (PCAOB or the board) Firm Reporting (the proposal)
April 9, 2024
Proposals Regarding False or Misleading Statements Concerning PCAOB Registration and Oversight and Constructive Requests to Withdraw from Registration
March 18, 2024
Roundtable Discussion of Proposed Amendments to PCAOB Auditing Standards Related to a Company’s Noncompliance with Laws and Regulation
August 25, 2023
PCAOB proposed Amendments Related to Aspects of Designing and Performing Audit Procedures that Involve Technology-Assisted Analysis of Information in Electronic Form (the proposal, the release)
August 7, 2023
PCAOB Auditing Standards related to a Company’s Noncompliance with Laws and Regulations And Other Related Amendments
May 25, 2023
PCAOB proposed Auditing Standard, General Responsibilities of the Auditor in Conducting an Audit, and Proposed Amendments to PCAOB Standards (the proposed standard)
February 20, 2023
PCAOB proposed Auditing Standard, The Auditor’s Use of Confirmation, and Other Proposed Amendments to PCAOB Standards
February 1, 2023
PCAOB proposed new quality control standard, A Firm’s System of Quality Control and Other Proposed Amendments to PCAOB Standards, Rules, and Forms
October 26, 2022
Input on the PCAOB's Request for Information and Comment, The Application and Use of the PCAOB’s Interim Attestation Standards, issued on September 26, 2022
September 15, 2022
Comments for the PCAOB Request for Comment, Strategic Plan 2022–2026 – Draft for Comment
June 1, 2022
Comments on the PCAOB’s Request for Comment, Post-Implementation Review: Interim Analysis of Estimates and Specialists Audit Requirements
February 25, 2022
Comments on PCAOB Release No. 2022-001, Request for Public Comment: Advisory Groups – Draft Governance Frameworks
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