Re: the FASB staff's recent advice to one or more of the "big four" accounting firms that the grant date for financial measurement purposes under FAS 123(R) does not occur until the terms of the grant have been communicated to the employee
Mr. Robert H. Herz
Chairman, Financial Accounting Standards Board
401 Merritt 7, P.O. Box 5116
Norwalk, Connecticut 06856-5116
Dear Mr. Herz:
The Society of Corporate Secretaries & Governance Professionals wishes to offer comments on the FASB staff's recent advice to one or more of the "big four" accounting firms that the grant date for financial measurement purposes under FAS 123(R) does not occur until the terms of the grant have been communicated to the employee. This advice is inconsistent with current practice followed by most companies and is a topic of great concern to our members. We believe there are other means to achieve the goals of accurate financial reporting and transparency, without the difficulties and expense that this advice will cause for corporations, as explained in detail below.
See full Comment letter.
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