Spreadsheet: 014be948-3f5a-4429-83e0-b4b6e50eb39e
Sheet: Comprehensive Income Nov 2011

 |  | Proposed Accounting Standards Update, Comprehensive Income (Topic 220): Deferral of the Effective Date for Amendments to the Presentation of Reclassifications of Items Out of Accumulated Other Comprehensive Income in Accounting Standards Update No. 2011-05
 |  | Reference Number: 2011-240
 |  | Online Feedback Form Submissions
Record ID | (Q1SPECIFIED_7) 1_Entity_. Other, please specify Specify [Question: * Please select the type of entity or individual responding to this feedback form.] | Entity Name | Entity Type | Name of Individual Responding | 1. Do you agree with the deferral? Why or why not? | 2. Are there alternatives that the Board should consider for presenting reclassifications out of accumulated other comprehensive income that would be more cost effective than the one required by Update 2011-05? | 3. If you provide an alternative to question 2 above, please explain how your alternative would better serve the needs of users of financial statements than current requirements. | 4. Please provide any additional comments on how to clarify the drafting of the proposed requirements in the proposed Update or any comments on this electronic feedback process below. | (Q30) 24_RecapYN. * Would you like to view a summary of your responses to the questions in this feedback form? | (Q2) 25_Recap. Below is a summary of your responses to the questions in this feedback form: | (Q3) 26_ThankYou. Thank you for your participation in this electronic feedback form.If you are finished providing comments, click the Submit button. | Submitted
6.34576e+17 |  | KeyCorp | Preparer | [NAME] | Key agrees with the deferral of the effective date of the requirement to present reclassification adjustments for each component of accumulated other comprehensive income in both net income and other comprehensive income on the face of the financial statements.  This will allow the FASB time to reevaluate the need to show reclassifications in and out of accumulated other comprehensive income and how these items are best presented.  It is important to establish a better understanding of the costs associated with adopting these changes and more time is needed for this purpose.  In closing, Key agrees with the proposed deferral and encourages the Board to not only consider the costs and benefits of the proposed guidance but the overall impact it would have on the goal of convergence with IFRS. | Companies should be given the choice to either present the reclassification adjustments on the face of the financial statements or disclose these items in the notes to the financial statements.  This approach would further advance convergence between U.S. GAAP and IFRS on this issue. | N/A |  | Yes |  |  | 2011-11-22 00:00:00
6.34577e+17 |  | Bristol-Myers Squibb | Preparer | [NAME] | I support the deferral as adding such complexity to the income statement would be burdensome for preparers and ultimately be overly complex for readers of the financial statements to understand.  For example, pension benefits classified to net earnings from the OCI statement may need to be presented throughout multiple income statement line items depending upon respective employee internal classification.  Furthermore, reclassification from the OCI statement may not reconcile to the multiple income statement line items as certain companies may capitalize a portion of the costs in inventory or fixed assets which will get recognized in the income statement in several subsequent periods.  Furthermore, the reclassification adjustments are generally not significant to the individual income statement line items. |  |  |  | Yes |  |  | 2011-11-23 11:01:00