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George J. Benston et al., Comments by the American Accounting Association's Financial Accounting Standards Committee on the FASB's 'Conceptual Framework for Financial Reporting (Hereafter CF)', Call for Preliminary Views, July 6, 2006 (2006).

Abstract: The American Accounting Association's Financial Accounting Standards Committee is pleased to have an opportunity to express its views on the FASB's Call for Preliminary Views on its Conceptual Framework. We applaud the decision of the FASB to develop a Conceptual Framework and seek comments on its preliminary views and hope the financial reporting community will participate enthusiastically in this important activity. While we understand the importance of a Conceptual Framework, especially for accounting standard setting, we have deep reservations about the current document. In our response we explain why we think that the Preliminary Conceptual Framework is unlikely to be helpful in setting conceptually sound accounting standards. In particular, as you will see, we have reservations about the following key points: 1. We believe the Preliminary Conceptual framework is too focused on an investment role of accounting, and neglects the more important stewardship role of accounting. 2. The reliance on fair values that are not grounded on actual relevant market transactions (such as mark to model numbers) are not trustworthy. We believe that provision of soft accounting numbers will be harmful to the relevance and usefulness of accounting numbers. 3. We agree with the FASB's desire for neutral accounting numbers. However, given management's upward bias in reporting, we feel that conservative standards are required to produce neutral accounting numbers, and 4. We believe the FASB's standards should not be determined based only on a conceptual framework. Concepts such as relevance are too broad to be useful in determining a specific standard. A more rigorous field-performance-testing model is needed before conducting real world experiments with new accounting standards. We recommend allowing companies more flexibility in their reporting choices to allow market forces a greater role in setting accounting standards. In closing, despite our reservations about the Conceptual Framework, we applaud the FASB's desire to seek views on its preliminary effort and hope to participate again as this important activity progresses further.