1、)标题:Comment letter activity: A response to proposed changes in lease accounting作者:Fernando Comiran, Carol Graham期刊:Research in Accounting Regulation,28 卷,109-117 页年份:2016原文AbstractThis study examines the motivations that lead some firms to lobby, via comment letters, against the changes in accountin
2、g for leases proposed by FASB/IASB. There are at least three distinct motivations for a company to lobby against the proposed changes: a high perceived cost of implementation/operation, a belief that the changes will increase the cost of capital, and a desire on the part of management to avoid any a
3、dministrative burden associated with the changes. Our research suggests that companies that engage in lobbying are concerned with the costs of such changes (renegotiation of debt covenants, auditor fees, change in IT systems, etc.), but they also seem to be motivated by their accounting managers des
4、ire to avoid any additional effort that the changes will require.Keywords:Leases, Comment letters, FASB1. IntroductionAt the suggestion of the SEC in 2005, the FASB undertook acontroversial joint project with the IASB aimed at converging lease accounting standards. More than a decade later on Februa
5、ry 25, 2016, Accounting Standards Update (ASU) No. 2016-02 Leases was issued and will be effective for most companies after December 18, 2018.1 This report provides an analysis of the more than 1400 comment letters sent to the FASB/IASB in response to accounting changes proposed via ASC 840 and 842
6、Leases. Although the economic impact of the changes proposed by the FASB/IASB was not clear, they generated strong opposition from companies. Our analysis reveals that approximately 80% of the comment letter lobbying firms were against the proposed changes. While there is a substantial body of empir
7、ical research devoted to understanding the implications of lease accounting, little primary research has been conducted in this area. This paper provides an analysis of the entities that engaged in comment letter lobbying around this issue, the tone of the comment letters they sent, and a summary of
8、 the specific reasons they gave in opposition to the changes. We also provide some related empirical findings. The reasons for, and potential motivations behind, lobbying against what is arguably one of the most contentious issues in contemporary accounting, should be of interest to practitioners, r
9、egulators and academics alike. Consistent with prior studies (e.g. Anantharaman, 2015; Francis, 1987; Fried, 2012; Ramanna, 2008) we use the term lobbying in a narrow context, referring specifically to comment letterlobbying.The purpose of the joint project was to address concerns that the current s
10、tandard (SFAS 13) does not meet the needs of investors. More specifically, the existing accounting model has been criticized, among other reasons, because it represents one of the largest forms of off-balance sheet accounting and fails to provide a faithful representation of leasing transactions www
11、.fasb.org. The main effect of the new standard will be to end the use of operating leases and instead require capitalization of all leases. The FASBs objective was to increase financial statement comparability by preventing similar transactions from being reported differently, as currently happens d
12、ue to the bright-line rules of SFAS 132 that differentiate between operating and capital leases. Ex-ante, it is not clear why firms would lobby for or against the proposed changes. If stakeholders understand the implications of off-balance sheet leases, the changes should have minimal effect. Howeve
13、r, if a group of stakeholders is not correctly adjusting for operating leases, it is possible that the proposed changes could increase their risk assessment for companies. It is evident from the comment letters that most companies are against the proposed change. This study examines whether companie
14、s are opposed to the proposed lease changes because they wish to obfuscate their perceived risk, or because they perceive that the new rules will increase their operational costs or their cost of capital.This paper contributes to the current literature on lobbying by analyzing the specific objection
15、s to the proposed changes from the comment letters and by investigating whether lobbying firms have unique characteristics that could raise red flags for investors. This study also complements the current literature by analyzing the behavior of firms when management compensation is not expected to be negatively affected.2. Literature reviewThe Boards primary concern that current lease accounting does not always faithfully represent leasing transactions and, as such, may disadvantage some investors, is borne out by extant academic research but
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