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Business and Policy Areas
Business and Policy Areas

FASB Comment Deadline Quickly Approaching

August 10, 2015

The Financial Accounting Standards Board (FASB) is accepting comments through August 20 on its proposed Accounting Standards Update (ASU), "Presentation of Financial Statement of Not-for-Profit Entities," which outlines suggestions for improving the current reporting model. The ASU is a long-anticipated document that sets forth display and performance measurement changes.  

NACUBO has been tracking higher education opinions on FASB's proposal and has posted a Feedback Matrix and Comment Matrix on our dedicated FASB NFP Reporting Project webpage. Please use these tools to help organize your thoughts.

Institutions can submit a formal letter to FASB or use FASB's online feedback form. Institutions can also contact NACUBO with suggestions for the industry letter.  

NACUBO's comments will address all questions in the proposed ASU and provide alternative reporting examples and suggestions for FASB's consideration. Based on research with users and  feedback from business officers and NACUBO's Accounting Principles Council, NACUBO will address a variety of high-level concerns. NACUBO believes the proposal:

  • Goes beyond the originally defined scope of the project.
  • Introduces new concepts that result in sweeping changes, rather than the minor tweaks that the NFP Advisory Committee thought were necessary.
  • Attempts to bring in aspects of the now-defunct Financial Reporting Project, which was beyond the scope of this effort.
  • Establishes an unnecessarily prescriptive hard line distinction between operating, investing, and financing activities—including treating annual spending from quasi-endowments as non-operating.
  • Allows internal decisions to affect financial performance in the Statement of Activities (SOA) in a way that is confusing, potentially engineered, and difficult to explain to stakeholders.
  • Introduces two operating metrics that complicate the consistency and comparability objectives of the project.
  • Forces several reclassifications within the SOA for long-lived assets donated or constructed using donor restricted contributions, making such transactions impossible to follow.
  • Creates category changes to the Statement of Cash Flows that differ from the for-profit sector, which result in even more explanation.


Feedback Matrix and Comment Matrix
FASB's online feedback form


Sue Menditto
Director, Accounting Policy