Office of the Chief Accountant:
Staff Letters to Industry

• Letter from SEC Chief Accountant to Dan Palomaki, Chairman, Accounting Policy Committee, International Swaps and Derivatives Association, concerning accounting for hedging relationships when there is a change in counterparty (May 11, 2012)
   
• Letter from SEC Director of Corporation Finance and the SEC Chief Accountant to Cynthia M. Fornelli, Executive Director of the Center for Audit Quality, concerning Release No. 33-9002, Interactive Data to Improve Financial Reporting. (April 8, 2011)
   
• Letter from SEC Director of Trading and Markets and the SEC Chief Accountant to Stephen Zammitti, Chair of the AICPA Stockbrokerage and Investment Banking Expert Panel concerning requirements for broker-dealer annual audits pursuant to Rule 17A-5 under the Securities Exchange Act of 1934. (November 18, 2010)
   
• Letter from SEC Chief Accountant to Robert Herz, Chairman, Financial Accounting Standards Board concerning the assessment of declines in fair value for perpetual preferred securities under the existing other-than-temporary impairment model in Statement of Financial Accounting Standards No. 115, Account for Certain Investments in Debt and Equity Securities. (October 14, 2008)
   
• Letter from SEC Chief Accountant to Arnold Hanish, Chairman, Committee on Corporate Reporting, Financial Executive International and Sam Ranzilla, Chairman, Professional Practice Executive Committee, The Center for Audit Quality, American Institute of Certified Public Accountants concerning the American Securitization Forum’s Streamlined Foreclosure and Loss Avoidance Framework for Securitized Subprime Adjustable Rate Mortgage Loans. (January 8, 2008)
   
• Letter from SEC Chief Accountant to Zions Bancorporation concerning the use of Employee Stock Option Appreciation Rights Securities (ESOARS) to value employee share-based payment awards under FASB Statement No. 123R (October 17, 2007)
   
• Letter from SEC Chief Accountant to Council of Institutional Investors concerning the use of market instruments for the purpose of valuing employee share-based payment awards under FASB Statement No. 123R (February 23, 2007)
   
• Letter from SEC Chief Accountant to Zions Bancorporation concerning Zions Bancorporation’s proposal to issue Employee Stock Option Appreciation Rights Securities (ESOARS) for the purpose of valuing employee share-based payment awards under FASB Statement No. 123R (January 25, 2007)
   
• Letter from Chief Accountant to Lawrence Salva, Chairman, Committee on Corporate Reporting, Financial Executives International and Sam Ranzilla, Chairman, Center for Public Company Audit Firms, American Institute of Certified Public Accountants concerning accounting for stock options in the historical financial statements of public companies (September 19, 2006)
   
• Letter from Acting Chief Accountant to Deloitte & Touche LLP concerning the disposition of Deloitte & Touche Tax Technologies LLC and Deloitte Tax’s Tax Technology Services Division (July 5, 2006)
   
• Letter from Deputy Chief Accountant to Deloitte Touche Tohmatsu on the disposition of their controlling interest in Liberata plc (November 7, 2005)
   
• Letter from Deputy Chief Accountant to Deloitte Touche Tohmatsu concerning Deloitte Touche Tohmatsu's ("DTT") sale by its member firm in the United Kingdom, Deloitte & Touche LLP, of the Prophet software system and various other rights and assets (hereinafter collectively referred to as the "Prophet Assets"), to SunGard Sherwood Systems Group Ltd., (together with its parent corporation, SunGard Data Systems Inc., and the other affiliates and subsidiaries of SunGard Data Systems Inc. "SunGard") (October 21, 2005)
   
• Letter from Deputy Chief Accountant to Deloitte Touche Tohmatsu on the separation of various legal practices from their respective Deloitte Touche Tohmatsu member firms (June 7, 2005)
   
• Letter to Robert J. Kueppers, Chairman, Center for Public Company Audit Firms, from Donald T. Nicolaisen (February 7, 2005)
   
• Letter from the Deputy Chief Accountant to Deloitte Touche Tohmatsu on the disposition of its member firm's Spanish consulting practice, GMS Management Solutions, S.L. (January 18, 2005)
   
• Letter from SEC Chief Accountant to Eugene D. O'Kelly, Chairman & Chief Executive of KPMG LLP regarding an inaccurate statement in its letter to its clients (September 15, 2004)
   
• Letter from SEC Chief Accountant to Bruce P. Webb, Chair of the AICPA Professional Ethics Executive Committee regarding the receipt by an accounting firm of contingent fees for services provided to an audit client that is an SEC registrant (May 21, 2004)
   
• Letter from SEC Chief Accountant to KPMG LLP (UK), Concerning KPMG LLP's ("KPMG" or "KPMG Member Firms") separation of various legal practices from their respective KPMG Member Firms, May 14, 2004 (April 23, 2004)
   
• Letter from SEC Chief Accountant to Deloitte & Touche LLP, Concerning the Sale by its Member Firms Deloitte Consulting L.P., May 7, 2004 (May 6, 2004)
   
• Letter from SEC Chief Accountant to Deloitte Touche Tohmatsu, Concerning Deloitte Touche Tohmatsu's ("DTT") Sale by its Member Firms Deloitte SA and Deloitte Conseil SAS, April 27, 2004 (April 22, 2004)
   
• Letter from SEC Chief Accountant to Ernst & Young, Regarding the Initial Decision In the Matter of Ernst & Young LLP, April 16, 2004 (April 27, 2004)
   
• Letter from SEC Office of the Chief Accountant to Deloitte Touche Tohmatsu re: Auditor Independence (March 22, 2004)
   
• Letter from SEC Chief Accountant to AICPA re: Effective Date Provisions of FASB Interpretation No. 46 With Regard to Foreign Private Issuers (March 15, 2004)
   
• Sample Letter Sent to to Oil and Gas Producers (February 25, 2004)
   
• Memorandum from Scott A. Taub, Deputy Chief Accountant attached to letter from Chairman William H. Donaldson to Five Consumer Groups (July 11, 2003)
   
• Letter from SEC Deputy Chief Accountant to Ernst & Young re: Comments Published July 1, 2003 (July 8, 2003)
   
• Letter from SEC Acting Chief Accountant to the American Institute of Certified Public Accountants re: The Auditing Standards-Setting Process (March 18, 2003)
   
• Letter from SEC Acting Chief Accountant and Director of Division of Corporation Finance to the Institute of Chartered Accountants of England and Wales re: Use of Clarifying Language in UK Audit Opinions (February 28, 2003)
   
• Letter from SEC Chief Accountant to the Auditing Standards Board of the American Institute of Certified Public Accountants re: Auditors' Roles in Helping To Structure Transactions (February 13, 2002)
   
• Letter from SEC Chief Accountant to Joint Working Group of Standard Setters (c/o Tim Lucas, FASB) re: Draft Standard "Recommendations on Accounting for Financial Instruments and Similar Items" (July 24, 2001)
   
• Letter from SEC Chief Accountant to Arleen Thomas, VP Professional Standards and Services, AICPA, re: Concerns about Changes to the CPA Exam (July 23, 2001)
   
• Letter from SEC Chief Accountant to Sir David Tweedie, Chairman, IASB re: IASB Agenda (July 20, 2001)
   
• Letter from SEC Chief Accountant to FASB re: Revenue Recognition and EITF Issue 00-21 (July 19, 2001)
   
• Letter from SEC Chief Accountant to Letter to IASB re: Revenue Recognition and EITF Issue 00-21 (July 19, 2001)
   
• Letter from SEC Chief Accountant to Charles Bowsher, Chairman, Public Oversight Board (POB) re: Business Week article: "For Accountants, A Major Credibility GAAP" (July 18, 2001)
   
• Letter from SEC Chief Accountant to Edmund Jenkins, Chairman, FASB re: Implementing the O'Malley Panel's recommendations. (July 18, 2001)
   
• Letter from Chief Accountant to EITF on Accounting for Convertible Securities with Beneficial Conversion Features (July 16, 2001)
   
• Letter from SEC Chief Accountant to FASB and AcSEC Regarding Fair Value Accounting for the Securities Industry (May 11, 2001)
   
• Letter from SEC Chief Accountant Requesting AcSEC Take on Project on Mining Industry (May 10, 2001)
   
• Letter from SEC Chief Accountant to Accounting Standards Executive Committee addressing potential project on blockage factors (April 11, 2001)
   
• Letter From the SEC Chief Accountant re: Quality Controls to Public Oversight Board (April 9, 2001)
   
• Sample Letter Sent to Large Public Accounting Firms (March 22, 2001)
   
• Letter From the SEC Chief Accountant re: Public Oversight Board (February 9, 2001)
   
• Letter to Investment Company CFOs (from the Division of Investment Management) (February 2001)
   
• Letter from SEC Chief Accountant to Accounting Standards Executive Committee addressing potential project on blockage factors (November 30, 2000)
   
• Requesting AICPA to Assume Leadership Role in Identifying Key Performance Indicators (November 22, 2000)
   
• Requesting the AICPA To Provide Industry Guidance on Models and Methodologies for Valuation (November 17, 2000)
   
• Letter from SEC Chief Accountant to IFAC re: IFAC Oversight Organization (October 16, 2000)
   
• 2000 Audit Risk Alert to the American Institute of Certified Public Accountants (October 13, 2000)
   
• Letter from SEC Chief Accountant to Michael Conway, Chair, SECPS re: Implementing the O'Malley Panel's recommendations. (October 6, 2000)
   
• Letter From the SEC Chief Accountant to the Auditing Standards Board and SEC Practice Section re: Timely Review of Interim Financial Statements (October 6, 2000)
   
• Letter from SEC Chief Accountant to Deborah Lambert, Chair, Auditing Standards Board (ASB) re: Implementing the O'Malley Panel's recommendations. (September 19, 2000)
   
• Letter From the SEC Chief Accountant to the Public Oversight Board re: Independence Look-Back Testing Program (September 13, 2000)
   
• Letter: Issues Related to Independence/Quality Control to SEC Practice Section (III), Issued by the Office of the Chief Accountant (May 1, 2000)
   
• Letter From the SEC Chief Accountant re: Audit Risk (December 22, 1999)
   
• Letter From the SEC Chief Accountant to Auditing Standards Board re: Need for Additional Guidance on Revenue Recognition (Multiple Element Arrangements) and Loss Accruals (December 9, 1999)
   
• Letter From the SEC Chief Accountant re: Independence/QC to Public Oversight Board (December 9, 1999)
   
• Letter From the SEC Chief Accountant re: Independence/QC, SEC Practice Section (II) (December 9, 1999)
   
• Letter to Investment Company CFOs (from the Division of Investment Management) (December 1999)
   
• Letter From the SEC Chief Accountant re: Accounting Issues in Internet Operations (October 18, 1999)
   
• Letter to Investment Company CFOs (from the Division of Investment Management) (December 1998)
   
• Letter From the SEC Chief Accountant re: Independence/QC, SEC Practice Section (November 30, 1998)
   
• Commission Information: Letters re 1998/99 Audit Risk Alerts (October 9, 1998)